Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 21
... immediately preceding the close of such taxable year as may be applicable ) was derived from sources within a posses- Continued of the exclusion , and because dividends received by a ( 1 ) 21 COCA - COLA CO . & SUBS . v . COMMISSIONER.
... immediately preceding the close of such taxable year as may be applicable ) was derived from sources within a posses- Continued of the exclusion , and because dividends received by a ( 1 ) 21 COCA - COLA CO . & SUBS . v . COMMISSIONER.
Page 22
United States. Tax Court. of the exclusion , and because dividends received by a domes- tic corporation from its wholly owned possessions subsidiary were not eligible for the intercorporate dividends received deductions under section 246 ...
United States. Tax Court. of the exclusion , and because dividends received by a domes- tic corporation from its wholly owned possessions subsidiary were not eligible for the intercorporate dividends received deductions under section 246 ...
Page 27
... Court to rewrite the applicable regulations . We agree . We find that Exxon Corp. is distinguishable from the instant case . Exxon received a known and quantifiable amount of income from ( 1 ) 27 COCA - COLA CO . & SUBS . v . COMMISSIONER.
... Court to rewrite the applicable regulations . We agree . We find that Exxon Corp. is distinguishable from the instant case . Exxon received a known and quantifiable amount of income from ( 1 ) 27 COCA - COLA CO . & SUBS . v . COMMISSIONER.
Page 28
United States. Tax Court. Exxon received a known and quantifiable amount of income from sales of natural gas in 1979. Exxon claimed a 22 - percent depletion allowance on an amount larger than the actual sales proceeds from that gas ...
United States. Tax Court. Exxon received a known and quantifiable amount of income from sales of natural gas in 1979. Exxon claimed a 22 - percent depletion allowance on an amount larger than the actual sales proceeds from that gas ...
Page 70
... received from the Government . The temporary regu- lations address the situation of unidentifiable debt proceeds under the heading " Debt assumptions not involving cash disbursements . " Section 1.163-8T ( c ) ( 3 ) ( ii ) , Temporary ...
... received from the Government . The temporary regu- lations address the situation of unidentifiable debt proceeds under the heading " Debt assumptions not involving cash disbursements . " Section 1.163-8T ( c ) ( 3 ) ( ii ) , Temporary ...
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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