Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 60
Page 5
... QUALIFIED POSSESSION SOURCE INVESTMENT INCOME . - The term " qualified possession source investment income " means gross income which- ( A ) is from sources within a possession of the United States in which a trade or business is ...
... QUALIFIED POSSESSION SOURCE INVESTMENT INCOME . - The term " qualified possession source investment income " means gross income which- ( A ) is from sources within a possession of the United States in which a trade or business is ...
Page 63
... qualified interest . The deficiency interest paid by plaintiffs exceeded the amount they were entitled to deduct as qualified interest ; thus , plaintiffs may only fully deduct the deficiency interest if it constitutes a business ...
... qualified interest . The deficiency interest paid by plaintiffs exceeded the amount they were entitled to deduct as qualified interest ; thus , plaintiffs may only fully deduct the deficiency interest if it constitutes a business ...
Page 64
... qualified as a deduction " attributable to the operation of a trade or business " to compute a net operating loss under 122 ( d ) ( 5 ) of the 1939 tax code . To determine the interest's deductibility , the court examined whether the ...
... qualified as a deduction " attributable to the operation of a trade or business " to compute a net operating loss under 122 ( d ) ( 5 ) of the 1939 tax code . To determine the interest's deductibility , the court examined whether the ...
Page 85
... qualify as a " prevailing party " for purposes of section 7430 , petitioners must establish that : ( 1 ) The position of the United States in the proceeding was not substantially justified ; ( 2 ) they substantially prevailed with ...
... qualify as a " prevailing party " for purposes of section 7430 , petitioners must establish that : ( 1 ) The position of the United States in the proceeding was not substantially justified ; ( 2 ) they substantially prevailed with ...
Page 88
... qualified person " as defined under sec . 4975 ( e ) ( 2 ) ( A ) . Furthermore , as petitioner was the sole individual for whose benefit IRA # 1 was established , IRA # 1 itself was a disqualified person pur- suant to sec . 4975 ( e ) ...
... qualified person " as defined under sec . 4975 ( e ) ( 2 ) ( A ) . Furthermore , as petitioner was the sole individual for whose benefit IRA # 1 was established , IRA # 1 itself was a disqualified person pur- suant to sec . 4975 ( e ) ...
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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