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 4
... of sec . 7491 ( a ) have been met . Moreover , because there are no factual issues in dispute , sec . 7491 ( a ) does not apply . cipal residence for at least 2 of the 5 years 4 ( 1 ) 135 UNITED STATES TAX COURT REPORTS.
... of sec . 7491 ( a ) have been met . Moreover , because there are no factual issues in dispute , sec . 7491 ( a ) does not apply . cipal residence for at least 2 of the 5 years 4 ( 1 ) 135 UNITED STATES TAX COURT REPORTS.
Page 6
... apply accepted principles of statutory construction to ascertain 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 ...
... apply accepted principles of statutory construction to ascertain 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 ...
Page 7
... 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 ) is ambiguous , we may examine ...
... 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 ) is ambiguous , we may examine ...
Page 10
... apply only if the dwelling the taxpayer sells was actually used as his principal residence for the period required by section 121 ( a ) . The conclusion that we reach from an examination of the legislative history surrounding the ...
... apply only if the dwelling the taxpayer sells was actually used as his principal residence for the period required by section 121 ( a ) . The conclusion that we reach from an examination of the legislative history surrounding the ...
Page 12
... apply in situations where a taxpayer has dis- posed of his old dwelling . " Id . at 503. Because the taxpayers did not dispose of their dwelling , the Court concluded that former section 1034 was inapplicable . Id . Other cases have ...
... apply in situations where a taxpayer has dis- posed of his old dwelling . " Id . at 503. Because the taxpayers did not dispose of their dwelling , the Court concluded that former section 1034 was inapplicable . Id . Other cases have ...
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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