Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 59
Page 5
... 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 taxpayer in the active conduct of such trade or business , and ( B ) the qualified possession ...
... 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 taxpayer in the active conduct of such trade or business , and ( B ) the qualified possession ...
Page 6
... trade name , or brand name ; ( iv ) franchise , license , or contract ; ( v ) ... trade or busi- ness in a possession with respect to such product or type of service ... business in a possession with respect to units of a prod- uct produced ...
... trade name , or brand name ; ( iv ) franchise , license , or contract ; ( v ) ... trade or busi- ness in a possession with respect to such product or type of service ... business in a possession with respect to units of a prod- uct produced ...
Page 7
... trade names , brand names , franchises , licenses and contracts , methods ... business income with respect to the product for which the election is made ... trades , or businesses ( whether or not incorporated , whether or not organized ...
... trade names , brand names , franchises , licenses and contracts , methods ... business income with respect to the product for which the election is made ... trades , or businesses ( whether or not incorporated , whether or not organized ...
Page 21
... businesses at a competitive disadvantage when compared with their British and French counterparts not subject to taxation upon ... trade or business " test.6 Because 6 Sec . 931 provided as follows : SEC . 931. INCOME FROM SOURCES WITHIN ...
... businesses at a competitive disadvantage when compared with their British and French counterparts not subject to taxation upon ... trade or business " test.6 Because 6 Sec . 931 provided as follows : SEC . 931. INCOME FROM SOURCES WITHIN ...
Page 22
... TRADE OR BUSINESS . - If- ( A ) in the case of such corporation , 50 percent or more of its gross income ( computed with- out the benefit of this section ) for such period or such part thereof was derived from the active conduct of a trade ...
... TRADE OR BUSINESS . - If- ( A ) in the case of such corporation , 50 percent or more of its gross income ( computed with- out the benefit of this section ) for such period or such part thereof was derived from the active conduct of a trade ...
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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