Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 67
Page 2
... tioner . Beth Williams , H. Steven New , and David P. Fuller , for respondent . OPINION WRIGHT , Judge : This matter is before the Court on petitioner's motion for partial summary judgment filed under Rule 121.1 This case was heard at a ...
... tioner . Beth Williams , H. Steven New , and David P. Fuller , for respondent . OPINION WRIGHT , Judge : This matter is before the Court on petitioner's motion for partial summary judgment filed under Rule 121.1 This case was heard at a ...
Page 4
... tioner was not entitled to the amount of the section 936 tax credit claimed on its returns for the years at issue . The peti- tion in the instant case was filed January 4 , 1994. On Janu- ary 12 , 1994 , respondent's proposed amendment ...
... tioner was not entitled to the amount of the section 936 tax credit claimed on its returns for the years at issue . The peti- tion in the instant case was filed January 4 , 1994. On Janu- ary 12 , 1994 , respondent's proposed amendment ...
Page 14
... tioner argues , the example provided in Q & A - 12 supports the plain meaning of the regulation . Respondent contends that on the facts before us , section 936 ( h ) ( 5 ) ( C ) ( ii ) ( II ) , as interpreted by Q & A - 1 , requires ...
... tioner argues , the example provided in Q & A - 12 supports the plain meaning of the regulation . Respondent contends that on the facts before us , section 936 ( h ) ( 5 ) ( C ) ( ii ) ( II ) , as interpreted by Q & A - 1 , requires ...
Page 16
... tioner argues , the Commissioner chose to ( 1 ) make Q & A - 12 the exclusive procedure for computing CTI with respect to component possession products and ( 2 ) chose to use a for- mulary apportionment method in order to make such com ...
... tioner argues , the Commissioner chose to ( 1 ) make Q & A - 12 the exclusive procedure for computing CTI with respect to component possession products and ( 2 ) chose to use a for- mulary apportionment method in order to make such com ...
Page 25
... tioner , however , has relatively low PCR's with respect to its component product , which , as stated earlier , results in a quite favorable tax benefit . The use of a formula will cut both ways ; it will be beneficial to some and not ...
... tioner , however , has relatively low PCR's with respect to its component product , which , as stated earlier , results in a quite favorable tax benefit . The use of a formula will cut both ways ; it will be beneficial to some and not ...
Contents
268 | |
274 | |
312 | |
319 | |
325 | |
340 | |
355 | |
361 | |
103 | |
110 | |
114 | |
117 | |
137 | |
142 | |
144 | |
155 | |
160 | |
185 | |
207 | |
216 | |
237 | |
245 | |
251 | |
257 | |
386 | |
392 | |
393 | |
394 | |
401 | |
405 | |
418 | |
419 | |
420 | |
430 | |
431 | |
432 | |
436 | |
450 | |
451 | |
461 | |
Other editions - View all
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