Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 5
... taxpayer in the active conduct of such trade or business , and ( B ) the qualified possession source investment income . * * * * * * ( d ) DEFINITIONS AND SPECIAL RULES . - For purposes of this section- * * * * ( 2 ) QUALIFIED ...
... taxpayer in the active conduct of such trade or business , and ( B ) the qualified possession source investment income . * * * * * * ( d ) DEFINITIONS AND SPECIAL RULES . - For purposes of this section- * * * * ( 2 ) QUALIFIED ...
Page 16
... taxpayer , depending on the circumstances , respondent should not be permitted to selectively enforce the provision by challenging its application for particular taxpayers . Peti- tioner acknowledges that it obtains favorable results by ...
... taxpayer , depending on the circumstances , respondent should not be permitted to selectively enforce the provision by challenging its application for particular taxpayers . Peti- tioner acknowledges that it obtains favorable results by ...
Page 25
... taxpayer's PCR is 80 percent . This is because the production costs incurred at the posses- sions level are high relative to total production costs . Peti- tioner , however , has relatively low PCR's with respect to its component ...
... taxpayer's PCR is 80 percent . This is because the production costs incurred at the posses- sions level are high relative to total production costs . Peti- tioner , however , has relatively low PCR's with respect to its component ...
Page 28
... taxpayer's " gross income from the property " . Section 611 ( a ) provides that reasonable depletion allowance in all cases is to be made under regulations prescribed by the Secretary . Although the statute was silent as to the ...
... taxpayer's " gross income from the property " . Section 611 ( a ) provides that reasonable depletion allowance in all cases is to be made under regulations prescribed by the Secretary . Although the statute was silent as to the ...
Page 33
... taxpayer , if such trade or business does not consist of the performance of services by the tax- payer as an employee . Section 162 ( a ) provides in part : There shall be allowed as a deduction all the ordinary and necessary expenses ...
... taxpayer , if such trade or business does not consist of the performance of services by the tax- payer as an employee . Section 162 ( a ) provides in part : There shall be allowed as a deduction all the ordinary and necessary expenses ...
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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