Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 66
Page 9
... purchased from a U.S. affiliate ) attrib- utable to the possession product , and its expenses allocable and apportionable to the integrated product under sec . 1.861-8 , as described in question and answer 1 of this paragraph ( b ) ( 1 ) ...
... purchased from a U.S. affiliate ) attrib- utable to the possession product , and its expenses allocable and apportionable to the integrated product under sec . 1.861-8 , as described in question and answer 1 of this paragraph ( b ) ( 1 ) ...
Page 81
... purchase all of the stock of Swansons ' Worldwide . At the time of the purchase , Mr. Swanson was the sole director of Swansons ' Worldwide . The sale of stock by Swansons ' Worldwide to Mr. Swanson's Individual Retirement Account ...
... purchase all of the stock of Swansons ' Worldwide . At the time of the purchase , Mr. Swanson was the sole director of Swansons ' Worldwide . The sale of stock by Swansons ' Worldwide to Mr. Swanson's Individual Retirement Account ...
Page 93
... purchase of a personal residence , we do not find it unreason- able that respondent would challenge the sale as not being at arm's length . Based on the record as a whole , we cannot say that respondent's position with respect to the ...
... purchase of a personal residence , we do not find it unreason- able that respondent would challenge the sale as not being at arm's length . Based on the record as a whole , we cannot say that respondent's position with respect to the ...
Page 105
... purchased with the card , under certain conditions , the cardholder may have had the right not to pay the remaining ... purchase goods and services , but pays off the entire balance each month , thereby avoiding any finance charges ...
... purchased with the card , under certain conditions , the cardholder may have had the right not to pay the remaining ... purchase goods and services , but pays off the entire balance each month , thereby avoiding any finance charges ...
Page 108
... purchase an airline ticket . Similarly , rental car insurance was provided when the cardholder charged the rental to the card . The amount of the annual fee to be charged was limited by competitive factors in the industry . The annual ...
... purchase an airline ticket . Similarly , rental car insurance was provided when the cardholder charged the rental to the card . The amount of the annual fee to be charged was limited by competitive factors in the industry . The annual ...
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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