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 83
Page 28
... assets ( " Properties " ) to be pledged as security , the details of which financing and Properties are to be set out in loan term sheets and attached hereto as Schedule ( s ) A ( " Schedule ( s ) A ” ) . The schedule D to be executed ...
... assets ( " Properties " ) to be pledged as security , the details of which financing and Properties are to be set out in loan term sheets and attached hereto as Schedule ( s ) A ( " Schedule ( s ) A ” ) . The schedule D to be executed ...
Page 49
... assets , such as cattle . See Grodt & McKay Realty , Inc. v . Commissioner , 77 T.C. 1221 , 1237 ( 1981 ) . For fungible securities , however , a more focused inquiry - whether legal title to the assets and 1 Sec . 1036 ( a ) provides ...
... assets , such as cattle . See Grodt & McKay Realty , Inc. v . Commissioner , 77 T.C. 1221 , 1237 ( 1981 ) . For fungible securities , however , a more focused inquiry - whether legal title to the assets and 1 Sec . 1036 ( a ) provides ...
Page 51
... assets by now Professor Edward Kleinbard . See Kleinbard , " Risky and Riskless Positions in Securities " , 71 Taxes 783 ( 1993 ) . 3 Apparently , Judge Holmes and I differ on whether petitioner disposed of his stock on Aug. 16 , 2001 ...
... assets by now Professor Edward Kleinbard . See Kleinbard , " Risky and Riskless Positions in Securities " , 71 Taxes 783 ( 1993 ) . 3 Apparently , Judge Holmes and I differ on whether petitioner disposed of his stock on Aug. 16 , 2001 ...
Page 65
... assets *** to be pledged as security . " The services promised in Section 1 include “ [ p ] roviding or arranging financing by way of one or more loans " and " [ h ] olding cash , securities , or other liquid assets * * * as collateral ...
... assets *** to be pledged as security . " The services promised in Section 1 include “ [ p ] roviding or arranging financing by way of one or more loans " and " [ h ] olding cash , securities , or other liquid assets * * * as collateral ...
Page 71
... assets was improperly omitted from the gross estate of Dorothy Dillon Eweson ( Ms. Eweson ) , resulting in a possible $ 75 million underpayment in Federal estate tax . He learned of the alleged omission by representing the widow of Ms ...
... assets was improperly omitted from the gross estate of Dorothy Dillon Eweson ( Ms. Eweson ) , resulting in a possible $ 75 million underpayment in Federal estate tax . He learned of the alleged omission by representing the widow of Ms ...
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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