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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Results 1-5 of 52
Page 1
... 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. Held : Ps may not exclude from their income , under sec . 121 ( a ) ...
... 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. Held : Ps may not exclude from their income , under sec . 121 ( a ) ...
Page 2
... exclude from gross income $ 500,000 of cap- ital gain from the sale in 2000 of property on Summit Road in Santa Barbara , California ( Summit Road property ) , under section 121 ( a ) ; and ( 2 ) whether petitioners are liable for the ...
... exclude from gross income $ 500,000 of cap- ital gain from the sale in 2000 of property on Summit Road in Santa Barbara , California ( Summit Road property ) , under section 121 ( a ) ; and ( 2 ) whether petitioners are liable for the ...
Page 4
... exclude $ 500,000 of the gain under section 121. Petitioners also argue that because they are not liable for a deficiency , respondent erred in determining that they were liable for the section 6651 ( a ) ( 1 ) addition to tax ...
... exclude $ 500,000 of the gain under section 121. Petitioners also argue that because they are not liable for a deficiency , respondent erred in determining that they were liable for the section 6651 ( a ) ( 1 ) addition to tax ...
Page 5
... exclusion is $ 500,000 for a husband and wife who file a joint return for the year of the sale or exchange . Sec . 121 ( b ) ( 2 ) . A married couple may claim the $ 500,000 exclusion on the sale or exchange of property they owned and ...
... exclusion is $ 500,000 for a husband and wife who file a joint return for the year of the sale or exchange . Sec . 121 ( b ) ( 2 ) . A married couple may claim the $ 500,000 exclusion on the sale or exchange of property they owned and ...
Page 6
... Exclusions from income must be construed narrowly , and taxpayers must bring themselves within the clear scope of the exclusion . See Commissioner v . Schleier , 515 U.S. 323 , 328 ( 1995 ) ; Dobra v . Commissioner , 111 T.C. 339 , 349 ...
... Exclusions from income must be construed narrowly , and taxpayers must bring themselves within the clear scope of the exclusion . See Commissioner v . Schleier , 515 U.S. 323 , 328 ( 1995 ) ; Dobra v . Commissioner , 111 T.C. 339 , 349 ...
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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