Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 68
Page 81
... termination of IRA's # 1 and # 2 ; and ( 2 ) the sale of the Algonquin property to a trust in 1986 was a " sham " trans- action which could not be recognized for tax purposes . a . " Prohibited Transactions " Because the notice of ...
... termination of IRA's # 1 and # 2 ; and ( 2 ) the sale of the Algonquin property to a trust in 1986 was a " sham " trans- action which could not be recognized for tax purposes . a . " Prohibited Transactions " Because the notice of ...
Page 134
... termination of the marital trust , any assets remaining after payment of estate , inheritance , and succession taxes arising from the surviving spouse's death are to be added to the family trust created under Article V of the will ...
... termination of the marital trust , any assets remaining after payment of estate , inheritance , and succession taxes arising from the surviving spouse's death are to be added to the family trust created under Article V of the will ...
Page 137
... terminate or fail " on the lapse of time , on the occurrence of an event or contingency , or on the failure of an event or contingency to occur " . Sec . 2056 ( b ) ( 1 ) . Accordingly , an interest in the nature of a life estate ...
... terminate or fail " on the lapse of time , on the occurrence of an event or contingency , or on the failure of an event or contingency to occur " . Sec . 2056 ( b ) ( 1 ) . Accordingly , an interest in the nature of a life estate ...
Page 141
... termination upon the occurrence of a specified event ( e.g. , remarriage ) , is not a quali- fying income interest for life . In addition , an income interest ( or life estate ) that is contingent upon the executor's election under ...
... termination upon the occurrence of a specified event ( e.g. , remarriage ) , is not a quali- fying income interest for life . In addition , an income interest ( or life estate ) that is contingent upon the executor's election under ...
Page 171
... termination of the surviving spouse's interest that would , under prior law , have violated the terminable interest rule . Clearly , by providing for an election , Congress ' purpose also was to allow some post mortem tax planning . I ...
... termination of the surviving spouse's interest that would , under prior law , have violated the terminable interest rule . Clearly , by providing for an election , Congress ' purpose also was to allow some post mortem tax planning . I ...
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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