Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 69
Page 21
... PERIOD . - If 80 percent or more of the gross income of such citizen or domes- tic corporation ( computed without the benefit of this section ) for the 3 - year period immediately preceding the close of the taxable year ( or for such ...
... PERIOD . - If 80 percent or more of the gross income of such citizen or domes- tic corporation ( computed without the benefit of this section ) for the 3 - year period immediately preceding the close of the taxable year ( or for such ...
Page 22
... period as long as 10 to 15 years and no tax is paid to the United States as long as no dividends are paid to the parent corporation . Because no current U.S. tax is imposed on the earnings if they are not repatriated , the amount of ...
... period as long as 10 to 15 years and no tax is paid to the United States as long as no dividends are paid to the parent corporation . Because no current U.S. tax is imposed on the earnings if they are not repatriated , the amount of ...
Page 46
... period of time for considering its impact . The second action is a 1990 proposal of the Senate Finance Committee to amend section 163 by eliminating the deduc- tion for corporate taxpayers of interest on income tax defi- ciencies . In ...
... period of time for considering its impact . The second action is a 1990 proposal of the Senate Finance Committee to amend section 163 by eliminating the deduc- tion for corporate taxpayers of interest on income tax defi- ciencies . In ...
Page 77
... period of entrench- ment ensued , during which the parties firmly established their respective positions , neither side wavering from its conviction that it was in the right . Ultimately , however , these issues were resolved by ...
... period of entrench- ment ensued , during which the parties firmly established their respective positions , neither side wavering from its conviction that it was in the right . Ultimately , however , these issues were resolved by ...
Page 78
... period , petitioner also arranged for the formation of an individual retirement account ( hereinafter IRA # 1 ) . The articles of incorporation for Worldwide were filed on January 9 , 1985 , and under the terms thereof petitioner was ...
... period , petitioner also arranged for the formation of an individual retirement account ( hereinafter IRA # 1 ) . The articles of incorporation for Worldwide were filed on January 9 , 1985 , and under the terms thereof petitioner was ...
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Common terms and phrases
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