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 1
... deficiency , R determined that Ps are not entitled to the $ 500,000 exclusion under sec . 121 ( a ) , I.R.C. , and that Ps are liable for a deficiency in income tax and an addition to tax under sec . 6651 ( a ) ( 1 ) , I.R.C. , for 2000 ...
... deficiency , R determined that Ps are not entitled to the $ 500,000 exclusion under sec . 121 ( a ) , I.R.C. , and that Ps are liable for a deficiency in income tax and an addition to tax under sec . 6651 ( a ) ( 1 ) , I.R.C. , for 2000 ...
Page 3
... deficiency for 2000 that increased petitioners ' income by $ 500,0009 and explained that peti- tioners had failed to establish that any of the gain on the sale of the Summit Road property was excludable under sec- tion 121. Respondent ...
... deficiency for 2000 that increased petitioners ' income by $ 500,0009 and explained that peti- tioners had failed to establish that any of the gain on the sale of the Summit Road property was excludable under sec- tion 121. Respondent ...
Page 4
... deficiency , respondent erred in determining that they were liable for the section 6651 ( a ) ( 1 ) addition to tax . Discussion I. Burden of Proof Ordinarily , the Commissioner's determination is entitled to a presumption of ...
... deficiency , respondent erred in determining that they were liable for the section 6651 ( a ) ( 1 ) addition to tax . Discussion I. Burden of Proof Ordinarily , the Commissioner's determination is entitled to a presumption of ...
Page 69
... deficiency if we found his trans- action to be a bona fide loan . The Commissioner hasn't made any claim for this little bit of extra deficiency , so he wouldn't get it . See Baker v . Commissioner , T.C. Memo . 2008-247 ( citing Estate ...
... deficiency if we found his trans- action to be a bona fide loan . The Commissioner hasn't made any claim for this little bit of extra deficiency , so he wouldn't get it . See Baker v . Commissioner , T.C. Memo . 2008-247 ( citing Estate ...
Page 78
... deficiencies in the personal income tax of P - PA , the sole shareholder of P - AC , as a result of adjustments including in his income a distributive share of ... deficiency case turns on the 78 ( 78 ) 135 UNITED STATES TAX COURT REPORTS.
... deficiencies in the personal income tax of P - PA , the sole shareholder of P - AC , as a result of adjustments including in his income a distributive share of ... deficiency case turns on the 78 ( 78 ) 135 UNITED STATES TAX COURT REPORTS.
Other editions - View all
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