Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 77
Page 9
... 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 to gross income from the sale of concentrate be apportioned in full ...
... 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 to gross income from the sale of concentrate be apportioned in full ...
Page 38
... position and held the tem- porary regulation a reasonable interpretation of the statute and therefore valid.6 Initially , we note that temporary regulations are accorded the same weight as final regulations . Peterson Marital Trust v ...
... position and held the tem- porary regulation a reasonable interpretation of the statute and therefore valid.6 Initially , we note that temporary regulations are accorded the same weight as final regulations . Peterson Marital Trust v ...
Page 45
... position would require us to substitute the word " always " for " generally " and to expand the interpretation of the word " deficiencies " beyond its accepted meaning to encompass taxes other than income , etc. , taxes in order to ...
... position would require us to substitute the word " always " for " generally " and to expand the interpretation of the word " deficiencies " beyond its accepted meaning to encompass taxes other than income , etc. , taxes in order to ...
Page 46
... positions not taken in the committee reports . " ) . Given the clear thrust of the conference committee report , the General Explanation is without foundation and must fall by the wayside . To conclude other- wise would elevate it to a ...
... positions not taken in the committee reports . " ) . Given the clear thrust of the conference committee report , the General Explanation is without foundation and must fall by the wayside . To conclude other- wise would elevate it to a ...
Page 48
... position herein , petitioners ' interest expense is not deductible " regardless " of the fact that it was clearly incurred by petitioners in connec- tion with , and that it is undisputably allocable to , petitioners ' business ...
... position herein , petitioners ' interest expense is not deductible " regardless " of the fact that it was clearly incurred by petitioners in connec- tion with , and that it is undisputably allocable to , petitioners ' business ...
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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