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 2
... effect for the year in issue , and all Rule references are to the Tax Court Rules of Practice and Proce- dure . 2 Petitioners concede that the destruction of the original house does not qualify as an involun- tary conversion under sec ...
... effect for the year in issue , and all Rule references are to the Tax Court Rules of Practice and Proce- dure . 2 Petitioners concede that the destruction of the original house does not qualify as an involun- tary conversion under sec ...
Page 11
... effect before its repeal . This Court held that in order to qualify under former section 1034 , a taxpayer had to sell a dwelling that he used as his principal residence . 16 In Hughes v . Commissioner , 54 T.C. 1049 , 1050 16 We have ...
... effect before its repeal . This Court held that in order to qualify under former section 1034 , a taxpayer had to sell a dwelling that he used as his principal residence . 16 In Hughes v . Commissioner , 54 T.C. 1049 , 1050 16 We have ...
Page 44
... effect a sale of the security in the ordinary course of the relevant market ( e.g. , by calling a broker to place a sale ) whenever the security is in - the - money . A significant impediment to the taxpayer's ability to effect such a ...
... effect a sale of the security in the ordinary course of the relevant market ( e.g. , by calling a broker to place a sale ) whenever the security is in - the - money . A significant impediment to the taxpayer's ability to effect such a ...
Page 63
... effect of the holding would be to treat all nonrecourse lending against stock collateral as sales . The majority does not appear to realize how startling that would be . V. The Grodt & McKay test , like other transaction tests , also ...
... effect of the holding would be to treat all nonrecourse lending against stock collateral as sales . The majority does not appear to realize how startling that would be . V. The Grodt & McKay test , like other transaction tests , also ...
Page 64
... effect decep- tion has on the characterization of the transaction . Deception should have been considered at a minimum under the Grodt & McKay factor regarding the parties ' treat- ment of the transaction , but the majority merely notes ...
... effect decep- tion has on the characterization of the transaction . Deception should have been considered at a minimum under the Grodt & McKay factor regarding the parties ' treat- ment of the transaction , but the majority merely notes ...
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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