Reports of the Tax Court of the United States, Volume 93U.S. Government Printing Office, 1989 |
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5th Cir action additions to tax administrative affd agreement amendments are effective amount Angola application assessment assets Belk charitable claimed Code Section Commis Commissioner corporation counsel decedent December 31 declaratory judgment deduction deposition determined distribution employees estate tax expenses fact fair market value farm filed FPAA gift tax gross estate held Income Tax Regs income tax return inter vivos trust interest Internal Revenue Code Internal Revenue Service inventory Iran issue July Krock loan loss method of accounting motion notice of deficiency paid paragraph partnership party payment percent period person petition petitioner Petitioner argues petitioner's preferred stock premium prior punitive damages purchase purposes pursuant qualified reasonable received references reinsurance reported request respect respondent's Rule shareholders shares sioner statute stipulation subparagraph supra surviving spouse T.C. Memo Tax Court taxable taxpayer tion transaction transfer trial trust United
Popular passages
Page 489 - ... organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or...
Page 916 - Use of depositions. — At the trial or upon the hearing of a motion or an interlocutory proceeding, any part or all of a deposition, so far as admissible under the rules of evidence applied as though the witness were then present and testifying...
Page 916 - If the deposition is not signed by the witness, the officer shall sign it and state on the record the fact of the waiver or of the illness or absence of the witness or the fact of the refusal to sign together with the reason, if any, given therefor; and the deposition may then be used as fully as though signed, unless...
Page 937 - Supporting and opposing affidavits shall be made on personal knowledge, shall set forth such facts as would be admissible in evidence, and shall show affirmatively that the affiant is competent to testify to the matters stated therein.
Page 96 - ... bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.
Page 896 - ... it is a sufficient answer to such interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries.
Page 376 - Plaintiff Sierra Club is a non-profit corporation organized and operating under the laws of the State of California, with its principal place of business in San Francisco, California since 1892.
Page 232 - ACRS is made on the taxpayer's return for the year in which the property is placed in service (Code Sec. 168(f)(4)).' Placed in Service. Property is considered placed in service when it is in a condition or state of readiness and availability for a specifically assigned function...
Page 868 - Such amendment of the pleadings as may be necessary to cause them to conform to the evidence and to raise these issues may be made upon motion of any party at any time, even after judgment...
Page 994 - If service is made by a person other than a United States marshal or his deputy, he shall make affidavit thereof.