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 14
... imposition of an addition to tax for failure to file a timely return , unless it is shown that such a failure is due ... impose the relevant penalty or addition to tax . Higbee v . Commissioner , supra at 446. However , the Commissioner ...
... imposition of an addition to tax for failure to file a timely return , unless it is shown that such a failure is due ... impose the relevant penalty or addition to tax . Higbee v . Commissioner , supra at 446. However , the Commissioner ...
Page 46
... imposed upon any portion of an underpayment where the taxpayer shows that he acted with reasonable cause and in good faith with respect to such portion . See sec . 6664 ( c ) ( 1 ) ; Higbee v . Commissioner , supra at 448. The ...
... imposed upon any portion of an underpayment where the taxpayer shows that he acted with reasonable cause and in good faith with respect to such portion . See sec . 6664 ( c ) ( 1 ) ; Higbee v . Commissioner , supra at 448. The ...
Page 49
... impose an accuracy - related penalty under section 6662 ( a ) . In reaching our holdings herein , we have considered all arguments made and , to the extent not mentioned above , we conclude they are moot , irrelevant , or without merit ...
... impose an accuracy - related penalty under section 6662 ( a ) . In reaching our holdings herein , we have considered all arguments made and , to the extent not mentioned above , we conclude they are moot , irrelevant , or without merit ...
Page 70
... imposition of penalties ( because Calloway did not respect his own characterization of the transaction as a loan ) . But unless future courts treat our analysis today as a limited - time ticket good only on Derivium cases , we may be ...
... imposition of penalties ( because Calloway did not respect his own characterization of the transaction as a loan ) . But unless future courts treat our analysis today as a limited - time ticket good only on Derivium cases , we may be ...
Page 97
... imposes a cor- porate - level tax on the net recognized built - in gain of an S corporation that has converted from C corporation to S cor- poration status . The tax generally applies to built - in gain recognized during the 10 - year ...
... imposes a cor- porate - level tax on the net recognized built - in gain of an S corporation that has converted from C corporation to S cor- poration status . The tax generally applies to built - in gain recognized during the 10 - year ...
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