Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 83
Page 8
... transactions must be used if such price can be determined in accordance with sec . 1.482-2 ( e ) ( 2 ) . If an independent sales price of the component product from comparable uncontrolled transactions cannot be determined , then the ...
... transactions must be used if such price can be determined in accordance with sec . 1.482-2 ( e ) ( 2 ) . If an independent sales price of the component product from comparable uncontrolled transactions cannot be determined , then the ...
Page 12
... transactions , or if an independent sale price from comparable uncontrolled transactions cannot be determined , then the sale price is determined using a production cost ratio method . This first requirement is not at issue for pur ...
... transactions , or if an independent sale price from comparable uncontrolled transactions cannot be determined , then the sale price is determined using a production cost ratio method . This first requirement is not at issue for pur ...
Page 49
... transaction involves interest expenses associated with the mere extension of credit , not the provision of funds ... transactions do not involve the disbursement of any loan proceeds but do involve the extension of credit and interest ...
... transaction involves interest expenses associated with the mere extension of credit , not the provision of funds ... transactions do not involve the disbursement of any loan proceeds but do involve the extension of credit and interest ...
Page 50
... transactions would be deductable under §162 * or §212 * * * , the principal function of §163 ( a ) is to permit the deduction of interest on consumer debt " ) . The courts also allowed an individual to deduct deficiency interest that ...
... transactions would be deductable under §162 * or §212 * * * , the principal function of §163 ( a ) is to permit the deduction of interest on consumer debt " ) . The courts also allowed an individual to deduct deficiency interest that ...
Page 76
... transactions had occurred under sec . 4975 , I.R.C. , with respect to a domestic inter- national sales corporation , a ... transaction . 1. Held , R was not substantially justified with respect to the first issue , but was substantially ...
... transactions had occurred under sec . 4975 , I.R.C. , with respect to a domestic inter- national sales corporation , a ... transaction . 1. Held , R was not substantially justified with respect to the first issue , but was substantially ...
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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