Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 2
... supra at 520 . I. Background Petitioner owns bottling companies known as company bot- tling operations ( CBO's ) , each of which is a domestic corpora- tion owned or controlled directly or indirectly by petitioner . Petitioner's ...
... supra at 520 . I. Background Petitioner owns bottling companies known as company bot- tling operations ( CBO's ) , each of which is a domestic corpora- tion owned or controlled directly or indirectly by petitioner . Petitioner's ...
Page 19
... supra at 800 ; Tate & Lyle , Inc. & Subs . v . Commissioner , supra at 666 ; Perkin - Elmer Corp. & Subs . v . Commissioner , 103 T.C. 464 ( 1994 ) . A legislative regulation is made pursuant to a specific grant of authority , often ...
... supra at 800 ; Tate & Lyle , Inc. & Subs . v . Commissioner , supra at 666 ; Perkin - Elmer Corp. & Subs . v . Commissioner , 103 T.C. 464 ( 1994 ) . A legislative regulation is made pursuant to a specific grant of authority , often ...
Page 20
... supra at 801 . As legislative regulations are essentially substantive rules of law , the rules of interpretation ... supra at 1498 . Thus , the party who seeks to convince a court to adopt a reading of a statute which is at odds with its ...
... supra at 801 . As legislative regulations are essentially substantive rules of law , the rules of interpretation ... supra at 1498 . Thus , the party who seeks to convince a court to adopt a reading of a statute which is at odds with its ...
Page 29
... supra at 728. We held further that the plain meaning rule does not preclude an examination behind the literal terms of the language at issue if the lack of such an exam- ination would compel an odd result . Exxon Corp. v . Commis ...
... supra at 728. We held further that the plain meaning rule does not preclude an examination behind the literal terms of the language at issue if the lack of such an exam- ination would compel an odd result . Exxon Corp. v . Commis ...
Page 31
... supra , is invalid insofar as it applies under the circumstances involved herein . Held , further , the amount of the interest so allocated by Ps is deductible as interest on an " indebtedness properly allocable to a trade or business ...
... supra , is invalid insofar as it applies under the circumstances involved herein . Held , further , the amount of the interest so allocated by Ps is deductible as interest on an " indebtedness properly allocable to a trade or business ...
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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