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 100
Page 32
... issue is whether the transaction , in which petitioner transferred his IBM stock to Derivium and received $ 93,586.23 , was a sale or a loan . Surprisingly , this case pre- 4 The Sept. 8 , 2004 , letter indicates that the collateral ...
... issue is whether the transaction , in which petitioner transferred his IBM stock to Derivium and received $ 93,586.23 , was a sale or a loan . Surprisingly , this case pre- 4 The Sept. 8 , 2004 , letter indicates that the collateral ...
Page 55
... issue in this case and the nonfungible and tangible property at issue in Grodt & McKay.1 One 1 Judge Halpern does recognize this important difference , and ( following some quite persuasive commentators ) urges us to adopt " control ...
... issue in this case and the nonfungible and tangible property at issue in Grodt & McKay.1 One 1 Judge Halpern does recognize this important difference , and ( following some quite persuasive commentators ) urges us to adopt " control ...
Page 66
... issue discounts " instead of charging interest . Lenders would extend a supposedly interest - free $ 95 loan , for example , but then require the borrower to repay $ 100 at the end of the term . See Travelers Ins . Co. v . United States ...
... issue discounts " instead of charging interest . Lenders would extend a supposedly interest - free $ 95 loan , for example , but then require the borrower to repay $ 100 at the end of the term . See Travelers Ins . Co. v . United States ...
Page 74
... issue guidance for the operation of a Whistleblower Office adminis- tered by the IRS . 4 TRHCA sec . 406 ( b ) ( 1 ) , 120 Stat . 2959. The Whistleblower Office is responsible for reviewing submitted whistleblower claims or assigning ...
... issue guidance for the operation of a Whistleblower Office adminis- tered by the IRS . 4 TRHCA sec . 406 ( b ) ( 1 ) , 120 Stat . 2959. The Whistleblower Office is responsible for reviewing submitted whistleblower claims or assigning ...
Page 79
... issue is whether this sale agreement with concurrent share lending requires TAC , and its parent , Anschutz Co. , to ... issue , and all Rule references are to the Tax Court Rules of Practice and Proce- dure . The stock transactions at ...
... issue is whether this sale agreement with concurrent share lending requires TAC , and its parent , Anschutz Co. , to ... issue , and all Rule references are to the Tax Court Rules of Practice and Proce- dure . The stock transactions at ...
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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