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 19
... consider a taxpayer whose longtime home is demolished by a natural disaster ( a hurricane ) . The taxpayer lacks insurance . Never- theless , she rebuilds on the same land ( perhaps a bit further from the ocean ) and lives in the ...
... consider a taxpayer whose longtime home is demolished by a natural disaster ( a hurricane ) . The taxpayer lacks insurance . Never- theless , she rebuilds on the same land ( perhaps a bit further from the ocean ) and lives in the ...
Page 37
... consider- ation of all the pertinent facts in the case . " Id . at 909. “ For disbursements to constitute true loans there must have been , at the time the funds were transferred , an unconditional obligation on the part of the ...
... consider- ation of all the pertinent facts in the case . " Id . at 909. “ For disbursements to constitute true loans there must have been , at the time the funds were transferred , an unconditional obligation on the part of the ...
Page 57
... Consider a true loan secured by stock . In most cases , creation of a security interest in stock is no longer delivering a physical certificate or noting the pledge on the books of the issuing corporation ; it's a matter of contracting ...
... Consider a true loan secured by stock . In most cases , creation of a security interest in stock is no longer delivering a physical certificate or noting the pledge on the books of the issuing corporation ; it's a matter of contracting ...
Page 67
... consider the conduct of both parties . But " intent " is not exactly the right word for what we think we should be looking for when one of the parties to a deal is trying to deceive another . Derivium's promises of a secret hedging ...
... consider the conduct of both parties . But " intent " is not exactly the right word for what we think we should be looking for when one of the parties to a deal is trying to deceive another . Derivium's promises of a secret hedging ...
Page 69
... Consider first an easy variation — a simple collateralized loan subject to the same standard contract lan- guage as in Derivium's forms . The stock stays in the lender's electronic equivalent of a desk drawer , the borrower repays the ...
... Consider first an easy variation — a simple collateralized loan subject to the same standard contract lan- guage as in Derivium's forms . The stock stays in the lender's electronic equivalent of a desk drawer , the borrower repays the ...
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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