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 15
... opinion . COHEN , J. , concurring : I agree with the majority and write to explain my disagreement with the dissent . The dissent argues that the holding of the majority is inconsistent with the remedial purpose of section 121. This ...
... opinion . COHEN , J. , concurring : I agree with the majority and write to explain my disagreement with the dissent . The dissent argues that the holding of the majority is inconsistent with the remedial purpose of section 121. This ...
Page 17
... opinion that would apply to all possible fact situations . We therefore focus upon the case before us and allow other facts to await their legal resolu- tion on another day . We have often stated that we " must decide the case in the ...
... opinion that would apply to all possible fact situations . We therefore focus upon the case before us and allow other facts to await their legal resolu- tion on another day . We have often stated that we " must decide the case in the ...
Page 18
... opinion . HALPERN , J. , dissenting : There is adequate ground for the majority's conclusion that , to qualify for the section 121 exclusion , the taxpayer must sell not only the land on which her principal residence is located but also ...
... opinion . HALPERN , J. , dissenting : There is adequate ground for the majority's conclusion that , to qualify for the section 121 exclusion , the taxpayer must sell not only the land on which her principal residence is located but also ...
Page 21
... exemption . Marcus S. Owens and Nancy Ortmeyer Kuhn , for peti- tioner . Philip T. Hackney and Michael B. Blumenfeld , for respondent . OPINION FOLEY , Judge : Pursuant to section 7428 ( ( 21 ) 21 FREE FERTILITY FOUND . v . COMMISSIONER.
... exemption . Marcus S. Owens and Nancy Ortmeyer Kuhn , for peti- tioner . Philip T. Hackney and Michael B. Blumenfeld , for respondent . OPINION FOLEY , Judge : Pursuant to section 7428 ( ( 21 ) 21 FREE FERTILITY FOUND . v . COMMISSIONER.
Page 22
United States. Tax Court. OPINION FOLEY , Judge : Pursuant to section 7428 ( a ) , 1 petitioner seeks a declaratory judgment that it meets the requirements of section 501 ( c ) ( 3 ) and is exempt from Federal income tax- ation . This ...
United States. Tax Court. OPINION FOLEY , Judge : Pursuant to section 7428 ( a ) , 1 petitioner seeks a declaratory judgment that it meets the requirements of section 501 ( c ) ( 3 ) and is exempt from Federal income tax- ation . This ...
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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