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 24
Page 180
... allowance for the exhaustion , wear and tear , and obsolescence of property used in a trade or business . For tan- gible property , section 168 ( a ) provides that the depreciation deduction of section 167 ( a ) is determined by using ...
... allowance for the exhaustion , wear and tear , and obsolescence of property used in a trade or business . For tan- gible property , section 168 ( a ) provides that the depreciation deduction of section 167 ( a ) is determined by using ...
Page 321
... allowances that effectively compensate for nonrecovery of such significant costs or expenses , is considered to permit recovery of such costs or expenses . A foreign tax whose base is gross receipts or gross income does not satisfy the ...
... allowances that effectively compensate for nonrecovery of such significant costs or expenses , is considered to permit recovery of such costs or expenses . A foreign tax whose base is gross receipts or gross income does not satisfy the ...
Page 322
... allowance for profit in respect of processing " ( processing allowance ) in lieu of certain expenses that were attributable to OMT gross receipts but 12 The test the Court of Claims adopted for the creditability of a foreign gross ...
... allowance for profit in respect of processing " ( processing allowance ) in lieu of certain expenses that were attributable to OMT gross receipts but 12 The test the Court of Claims adopted for the creditability of a foreign gross ...
Page 323
... allowance was likely to exceed nonrecoverable expenses for the tax years at issue . In answer to the Commissioner's objection that the taxpayer had not shown anything more than an accidental relationship between the processing allowance ...
... allowance was likely to exceed nonrecoverable expenses for the tax years at issue . In answer to the Commissioner's objection that the taxpayer had not shown anything more than an accidental relationship between the processing allowance ...
Page 324
... allowance greater than or equal to the disallowed interest expense , and we agreed with Exxon that the " PRT was designed to tax excess profits from North Sea oil and gas production [ , ] which generally were earned by major oil and gas ...
... allowance greater than or equal to the disallowed interest expense , and we agreed with Exxon that the " PRT was designed to tax excess profits from North Sea oil and gas production [ , ] which generally were earned by major oil and gas ...
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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