Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 4
... Respondent determined that peti- tioner was not entitled to the amount of the section 936 tax credit claimed on its ... respondent's proposed amendment to Q & A - 12 was published in the Federal Register . See infra note 5 . A secondary ...
... Respondent determined that peti- tioner was not entitled to the amount of the section 936 tax credit claimed on its ... respondent's proposed amendment to Q & A - 12 was published in the Federal Register . See infra note 5 . A secondary ...
Page 9
... 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 to such ...
... 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 to such ...
Page 10
... Respondent claims that Q & A - 12 must be read in the context of the statute and is to be applied only as a supplement to Q & A - 1 , which determines , according to respondent , the expenses allocable and apportionable to the ...
... Respondent claims that Q & A - 12 must be read in the context of the statute and is to be applied only as a supplement to Q & A - 1 , which determines , according to respondent , the expenses allocable and apportionable to the ...
Page 14
... Respondent contends that on the facts before us , section 936 ( h ) ( 5 ) ( C ) ( ii ) ( II ) , as interpreted by Q & A - 1 , requires that all expenses that USA incurs , and those CBO expenses that are factually related to concentrate ...
... Respondent contends that on the facts before us , section 936 ( h ) ( 5 ) ( C ) ( ii ) ( II ) , as interpreted by Q & A - 1 , requires that all expenses that USA incurs , and those CBO expenses that are factually related to concentrate ...
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 ...
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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