Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 1
... taxable income under sec . 936 ( h ) ( 5 ) ( C ) ( ii ) , I.R.C. , with respect to syrup and soft - drink concentrate produced by P's sec . 936 , I.R.C. , subsidiary , Carib- bean Refrescos , Inc. 1. Held , sec . 1.936-6 ( b ) ( 1 ) , Q ...
... taxable income under sec . 936 ( h ) ( 5 ) ( C ) ( ii ) , I.R.C. , with respect to syrup and soft - drink concentrate produced by P's sec . 936 , I.R.C. , subsidiary , Carib- bean Refrescos , Inc. 1. Held , sec . 1.936-6 ( b ) ( 1 ) , Q ...
Page 4
... taxable income under section 936. We are asked to decide whether petitioner may net interest income against interest expense in determining the amount of interest deduction to be allocated and apportioned in computing combined taxable ...
... taxable income under section 936. We are asked to decide whether petitioner may net interest income against interest expense in determining the amount of interest deduction to be allocated and apportioned in computing combined taxable ...
Page 5
... taxable income , from sources without the United States , from- ( i ) the active conduct of a trade or business within a possession of the United States , or ( ii ) the sale or exchange of substantially all of the assets used by the ...
... taxable income , from sources without the United States , from- ( i ) the active conduct of a trade or business within a possession of the United States , or ( ii ) the sale or exchange of substantially all of the assets used by the ...
Page 6
... taxable income derived from the active conduct of a trade or business in a possession with respect to units of a prod- uct produced * * * , in whole or in part , by the electing corporation shall be equal to 50 percent of the combined ...
... taxable income derived from the active conduct of a trade or business in a possession with respect to units of a prod- uct produced * * * , in whole or in part , by the electing corporation shall be equal to 50 percent of the combined ...
Page 7
... taxable income " derived from conducting business in a possession . Section 936 ( h ) determines the treat- ment of ... taxable income of the " electing corporation " , with respect to a product produced in a possession , is deemed to be ...
... taxable income " derived from conducting business in a possession . Section 936 ( h ) determines the treat- ment of ... taxable income of the " electing corporation " , with respect to a product produced in a possession , is deemed to be ...
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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