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. |
From inside the book
Results 1-5 of 100
Page 15
... agree with this majority opinion . COHEN , J. , concurring : I agree with the majority and write to explain my disagreement with the dissent . The dissent argues that the holding of the majority is inconsistent with the remedial purpose ...
... agree with this majority opinion . COHEN , J. , concurring : I agree with the majority and write to explain my disagreement with the dissent . The dissent argues that the holding of the majority is inconsistent with the remedial purpose ...
Page 18
... agree with this concurring opinion . HALPERN , J. , dissenting : There is adequate ground for the majority's conclusion that , to qualify for the section 121 exclusion , the taxpayer must sell not only the land on which her principal ...
... agree with this concurring opinion . HALPERN , J. , dissenting : There is adequate ground for the majority's conclusion that , to qualify for the section 121 exclusion , the taxpayer must sell not only the land on which her principal ...
Page 21
... agree with this dissent . FREE FERTILITY FOUNDATION , PETITIONER v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket No. 17122-07X . Filed July 7 , 2010 . P , a nonprofit corporation founded by S , provides S's sperm free of charge ...
... agree with this dissent . FREE FERTILITY FOUNDATION , PETITIONER v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket No. 17122-07X . Filed July 7 , 2010 . P , a nonprofit corporation founded by S , provides S's sperm free of charge ...
Page 26
... agreement with Derivium whereby P transferred 990 shares of IBM common stock to Derivium in exchange for $ 93,586.23 . The terms of the agree- ment characterized the transaction as a loan of 90 percent of the value of the IBM stock ...
... agreement with Derivium whereby P transferred 990 shares of IBM common stock to Derivium in exchange for $ 93,586.23 . The terms of the agree- ment characterized the transaction as a loan of 90 percent of the value of the IBM stock ...
Page 28
... Agreement to Provide Financing and Custodial Services " ( master agreement ) with attached " Schedule D , Disclosure Acknowledgement and Broker / Bank Indemnification " ( schedule D ) . The master agreement pro- vides , in pertinent ...
... Agreement to Provide Financing and Custodial Services " ( master agreement ) with attached " Schedule D , Disclosure Acknowledgement and Broker / Bank Indemnification " ( schedule D ) . The master agreement pro- vides , in pertinent ...
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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