Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 1
... parties . 2. Held , further , sec . 1.936-6 ( b ) ( 1 ) , Q & A - 12 , Income Tax Regs . , requires U.S. affiliate expenses to be allocated and apportioned to the component concentrate by applying the production cost ratio to all ...
... parties . 2. Held , further , sec . 1.936-6 ( b ) ( 1 ) , Q & A - 12 , Income Tax Regs . , requires U.S. affiliate expenses to be allocated and apportioned to the component concentrate by applying the production cost ratio to all ...
Page 8
... parties but rather are transferred to affiliates and used as component parts in the production of other products that are then sold by the affiliates to unre- lated parties . Congress directed the Secretary of the Treas- ury to write ...
... parties but rather are transferred to affiliates and used as component parts in the production of other products that are then sold by the affiliates to unre- lated parties . Congress directed the Secretary of the Treas- ury to write ...
Page 9
... parties which contains a component possession product . B. Parties ' Positions Respondent first argues that Q & A - 1 governs in the instant case , requiring that all expenses USA incurs and those CBO expenses that are factually related ...
... parties which contains a component possession product . B. Parties ' Positions Respondent first argues that Q & A - 1 governs in the instant case , requiring that all expenses USA incurs and those CBO expenses that are factually related ...
Page 11
... parties , CTI is determined as follows : Item Amount Gross income from the sale of concentrate per unit 1 Total USA expenses $ 2.24 ( 1.48 ) .76 Combined taxable income 1 Concentrate is sold in units ; syrup and soft drinks are sold in ...
... parties , CTI is determined as follows : Item Amount Gross income from the sale of concentrate per unit 1 Total USA expenses $ 2.24 ( 1.48 ) .76 Combined taxable income 1 Concentrate is sold in units ; syrup and soft drinks are sold in ...
Page 13
... parties acknowledge that regardless of the form in which the concentrate is sold , i.e. , one unit of concentrate , 79.26 gallons of syrup , or 515 gallons of soft drink , petitioner incurs approximately the same amount of expense with ...
... parties acknowledge that regardless of the form in which the concentrate is sold , i.e. , one unit of concentrate , 79.26 gallons of syrup , or 515 gallons of soft drink , petitioner incurs approximately the same amount of expense with ...
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1989 agreement 9th Cir affd allocable alternative minimum tax amended apply Arkla assets benefits business expense cardholder CBOT Citibank cluster home Commis Commissioner Congress contract corporation cost Court of Appeals debt decedent decedent's deduction determined election employees estate tax executor Federal income tax filed funds gross income Guardian Income Tax Regs Internal Revenue Code investment Irwindale issue litigation loan Los Angeles Raiders Malibu marital deduction MasterCard meals ment Mexican pesos Nihon Intergraph obligation overdraft amount paid parties payment percent peti petitioner Petitioner argues petitioner's possession product purchase purposes pursuant QTIP Raiders received refund regulations reinsurance reinsurance agreement Rept respondent's rule statute summary judgment supra surviving spouse T.C. Memo tax avoidance Tax Court tax deficiencies tax return taxable income taxpayer Temporary Income Tax terminable interest tion tioner trade or business transaction transfer fees trust United VEBA