Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 80
Page 4
... treat- ment of interest expense with respect to computing combined taxable income under section 936. We are asked to decide whether petitioner may net interest income against interest expense in determining the amount of interest ...
... treat- ment of interest expense with respect to computing combined taxable income under section 936. We are asked to decide whether petitioner may net interest income against interest expense in determining the amount of interest ...
Page 7
... treat- ment of intangible property income . Intangible property is broadly defined in section 936 ( h ) and includes ... treated as , the taxable income of the appro- priate U.S. affiliate or affiliates . Sec . 936 ( h ) ( 5 ) ( C ) ( ii ) ...
... treat- ment of intangible property income . Intangible property is broadly defined in section 936 ( h ) and includes ... treated as , the taxable income of the appro- priate U.S. affiliate or affiliates . Sec . 936 ( h ) ( 5 ) ( C ) ( ii ) ...
Page 8
... comparable uncontrolled transactions cannot be determined , then the possessions corporation must treat the sales price for the component product as equal to the same proportion of 8 ( 1 ) 106 UNITED STATES TAX COURT REPORTS.
... comparable uncontrolled transactions cannot be determined , then the possessions corporation must treat the sales price for the component product as equal to the same proportion of 8 ( 1 ) 106 UNITED STATES TAX COURT REPORTS.
Page 10
... treat a component product or an integrated product as its possession product even though the final stage or stages of production occur outside the possession . Id . Further processing includes transformation , incorporation , assembly ...
... treat a component product or an integrated product as its possession product even though the final stage or stages of production occur outside the possession . Id . Further processing includes transformation , incorporation , assembly ...
Page 42
... treated for purposes of this section as if the taxpayer used an amount of the debt pro- ceeds equal to the balance of the debt outstanding at such time to make an expenditure for such property , services , or other purpose . Under this ...
... treated for purposes of this section as if the taxpayer used an amount of the debt pro- ceeds equal to the balance of the debt outstanding at such time to make an expenditure for such property , services , or other purpose . Under this ...
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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