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 36
Page 24
... operations do not pro- mote health or otherwise serve a charitable purpose . Peti- 2 We need not and do not decide whether sec . 7491 ( a ) ( 1 ) applies to a declaratory judgment action . The applicability of sec . 7491 ( a ) ( 1 ) ...
... operations do not pro- mote health or otherwise serve a charitable purpose . Peti- 2 We need not and do not decide whether sec . 7491 ( a ) ( 1 ) applies to a declaratory judgment action . The applicability of sec . 7491 ( a ) ( 1 ) ...
Page 30
... $ 63 " Commission " ) . On August 22 , 2001 , the net proceeds from the sale of the IBM stock settled into Derivium's Morgan Keegan account . On or about August 17 , 2001 , Derivium's operations 30 ( 26 ) 135 UNITED STATES TAX COURT ...
... $ 63 " Commission " ) . On August 22 , 2001 , the net proceeds from the sale of the IBM stock settled into Derivium's Morgan Keegan account . On or about August 17 , 2001 , Derivium's operations 30 ( 26 ) 135 UNITED STATES TAX COURT ...
Page 31
United States. Tax Court. On or about August 17 , 2001 , Derivium's operations office sent to petitioner two documents . The first document , enti- tled “ Valuation Confirmation " , indicates that Derivium had received the IBM stock into ...
United States. Tax Court. On or about August 17 , 2001 , Derivium's operations office sent to petitioner two documents . The first document , enti- tled “ Valuation Confirmation " , indicates that Derivium had received the IBM stock into ...
Page 34
... operation and sale of the property . See id . at 252 ; see also Grodt & McKay Realty , Inc. v . Commissioner , supra at 1237–1238 . Applying the above factors leads us to the conclusion that petitioner sold his IBM stock to Derivium in ...
... operation and sale of the property . See id . at 252 ; see also Grodt & McKay Realty , Inc. v . Commissioner , supra at 1237–1238 . Applying the above factors leads us to the conclusion that petitioner sold his IBM stock to Derivium in ...
Page 59
... Operation and Sale of the Property . In today's world , when dealing with intangible , fungible securities , I agree with Judge Halpern that the benefits and burdens of ownership are " beside the point " in determining who is the owner ...
... Operation and Sale of the Property . In today's world , when dealing with intangible , fungible securities , I agree with Judge Halpern that the benefits and burdens of ownership are " beside the point " in determining who is the owner ...
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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