Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 4
... respondent's proposed amendment to Q & A - 12 was published in the Federal Register . See infra note 5 . A secondary dispute in the instant case involves the treat- ment of interest expense with respect to computing combined taxable ...
... respondent's proposed amendment to Q & A - 12 was published in the Federal Register . See infra note 5 . A secondary dispute in the instant case involves the treat- ment of interest expense with respect to computing combined taxable ...
Page 15
... respondent , by enacting language borrowed directly from section 861. Respondent argues that the phrase " properly apportioned or allocated " is a term of art borrowed verbatim from section 861 ( b ) , and enactment of this particu- lar ...
... respondent , by enacting language borrowed directly from section 861. Respondent argues that the phrase " properly apportioned or allocated " is a term of art borrowed verbatim from section 861 ( b ) , and enactment of this particu- lar ...
Page 17
... Respondent argues that petitioner's interpretation of Q & A- 12 improperly limits the role of Q & A - 1 , contrary to clear indications that Q & A - 1 must be accorded a broad scope . Respondent contends that petitioner's interpretation ...
... Respondent argues that petitioner's interpretation of Q & A- 12 improperly limits the role of Q & A - 1 , contrary to clear indications that Q & A - 1 must be accorded a broad scope . Respondent contends that petitioner's interpretation ...
Page 26
United States. Tax Court. Essentially , respondent is arguing that , at each level , the application of the PCR ... respondent's strained interpretation of the relationship between Q & A - 1 and Q & A - 12 is merely an attempt to ...
United States. Tax Court. Essentially , respondent is arguing that , at each level , the application of the PCR ... respondent's strained interpretation of the relationship between Q & A - 1 and Q & A - 12 is merely an attempt to ...
Page 27
... Respondent argues in the alternative that this Court's opinion in Exxon Corp. v . Commissioner , 102 T.C. 721 ( 1994 ) ... respondent's reliance on Exxon Corp. v . Commissioner , supra , is misplaced , and that respondent is essentially ...
... Respondent argues in the alternative that this Court's opinion in Exxon Corp. v . Commissioner , 102 T.C. 721 ( 1994 ) ... respondent's reliance on Exxon Corp. v . Commissioner , supra , is misplaced , and that respondent is essentially ...
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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