Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 57
Page 23
... share of the income generated from intangible assets . Congress recognized in enacting section 936 ( h ) that some section 936 corporations produce products that are not sold to unrelated parties , but rather are transferred to ...
... share of the income generated from intangible assets . Congress recognized in enacting section 936 ( h ) that some section 936 corporations produce products that are not sold to unrelated parties , but rather are transferred to ...
Page 62
... shares of the businesses ' incomes.2 Plaintiffs must endure the consequences of their choice of business form . Because they own shares of partnerships and S corporations , their 1986 interest payments are per- sonal deductions ...
... shares of the businesses ' incomes.2 Plaintiffs must endure the consequences of their choice of business form . Because they own shares of partnerships and S corporations , their 1986 interest payments are per- sonal deductions ...
Page 63
... shares of the partnerships ' and S corporations ' various items of income , gain , loss , deduction and credit . I.R.C. sections 701 , 702 ( a ) , 1366 ( a ) .6 A partner or shareholder's est from gross income as a business expense . 4 ...
... shares of the partnerships ' and S corporations ' various items of income , gain , loss , deduction and credit . I.R.C. sections 701 , 702 ( a ) , 1366 ( a ) .6 A partner or shareholder's est from gross income as a business expense . 4 ...
Page 78
... shares of Worldwide original issue stock . The shares were subsequently issued to IRA # 1 , which became the sole shareholder of Worldwide . For the taxable years 1985 to 1988 , Swansons ' Tool paid commissions to Worldwide with respect ...
... shares of Worldwide original issue stock . The shares were subsequently issued to IRA # 1 , which became the sole shareholder of Worldwide . For the taxable years 1985 to 1988 , Swansons ' Tool paid commissions to Worldwide with respect ...
Page 79
... shares of Swansons ' Trading stock . The shares were subse- quently issued to IRA # 2 , which became the corporation's sole shareholder . Swansons ' Trading filed a Form 8279 , Election To Be Treated as a FSC or as a Small FSC , on ...
... shares of Swansons ' Trading stock . The shares were subse- quently issued to IRA # 2 , which became the corporation's sole shareholder . Swansons ' Trading filed a Form 8279 , Election To Be Treated as a FSC or as a Small FSC , on ...
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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