Reports of the United States Tax Court, Volume 135United States Tax Court, 2010 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
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Page 6
... Congress ' intent . It is a well - established rule of construction that if a statute does not define a term , the term is given its ordinary meaning . See Perrin v . United States , 444 U.S. 37 , 42 ( 1979 ) ; Nw . Forest Res . Council ...
... Congress ' intent . It is a well - established rule of construction that if a statute does not define a term , the term is given its ordinary meaning . See Perrin v . United States , 444 U.S. 37 , 42 ( 1979 ) ; Nw . Forest Res . Council ...
Page 7
... Congress intended section 121 to apply to a sale of property when the property sold does not include the dwelling that the taxpayer used as a principal residence for the period that section 121 ( a ) requires . Because section 121 ( a ) ...
... Congress intended section 121 to apply to a sale of property when the property sold does not include the dwelling that the taxpayer used as a principal residence for the period that section 121 ( a ) requires . Because section 121 ( a ) ...
Page 8
... Congress recog- nized that many taxpayers faced hardship as a result of tax on gain realized on the sale of their principal residences— especially where a taxpayer was compelled to sell his prin- cipal residence and move to a new one ...
... Congress recog- nized that many taxpayers faced hardship as a result of tax on gain realized on the sale of their principal residences— especially where a taxpayer was compelled to sell his prin- cipal residence and move to a new one ...
Page 9
... Congress again amended former section 121 and repealed former sec- tion 1034. Section 121 as amended by TRA 1997 ( section 121 ) provides that a taxpayer generally may exclude up to $ 250,000 of gain realized on the sale or exchange of ...
... Congress again amended former section 121 and repealed former sec- tion 1034. Section 121 as amended by TRA 1997 ( section 121 ) provides that a taxpayer generally may exclude up to $ 250,000 of gain realized on the sale or exchange of ...
Page 10
... Congress intended the term " principal residence " to mean the primary dwelling or house that a taxpayer occupied as his principal residence . Nothing in the legislative history indicates that Congress intended section 121 to exclude ...
... Congress intended the term " principal residence " to mean the primary dwelling or house that a taxpayer occupied as his principal residence . Nothing in the legislative history indicates that Congress intended section 121 to exclude ...
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Common terms and phrases
accuracy-related penalty addition to tax adjustment allowance Appeals officer apply Appointments Clause assessment Caer's estate carryback CDP hearing Chesapeake claim Commissioner Congress corporation Court of Appeals Dalton deduction Derivium determination emphasis added equitable tolling estate tax Federal income tax filed forward contract gross income IBM stock Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue jurisdiction lake house lien loan loss ment notice of deficiency Ocean Pines Office of Appeals parties partner partnership item payment percent peti petition petitioner petitioner's principal residence provides purposes pursuant PVFCS refund regulations reported respect respondent's Rule schedule section 107 shares Stat statute street light assets supra T.C. Memo Tax Court tax imposed tax liability tax shown taxable taxpayer term Texasgulf tion tioner transaction transfer trust underpayment United Virgin Islands whistleblower windfall tax WISCO withholding credits