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 15
... parties , and to the extent not discussed above , conclude those arguments are irrelevant , moot , or without merit . To reflect the foregoing , Decision will be entered for respondent . Reviewed by the Court . COLVIN , COHEN , GALE ...
... parties , and to the extent not discussed above , conclude those arguments are irrelevant , moot , or without merit . To reflect the foregoing , Decision will be entered for respondent . Reviewed by the Court . COLVIN , COHEN , GALE ...
Page 17
... parties . Petitioners did not argue for a partial exclusion of gain attributable to the sale of the land , nor did peti- tioners introduce any evidence that would have permitted the Court to allocate gain between the new house and the ...
... parties . Petitioners did not argue for a partial exclusion of gain attributable to the sale of the land , nor did peti- tioners introduce any evidence that would have permitted the Court to allocate gain between the new house and the ...
Page 24
... parties held a conference on November 28 , 2006 , to discuss petitioner's application for exemption . On June 15 , 2007 , respondent issued a final determination letter denying petitioner's request for exemp- tion . On July 31 , 2007 ...
... parties held a conference on November 28 , 2006 , to discuss petitioner's application for exemption . On June 15 , 2007 , respondent issued a final determination letter denying petitioner's request for exemp- tion . On July 31 , 2007 ...
Page 32
... parties stipulate that the price per share of IBM stock was $ 105.03 on August 17 , 2001 , and approximately $ 84.16 on July 8 , 2004 . On February 11 , 2004 , petitioners filed their 2001 joint Federal income tax return . Petitioners ...
... parties stipulate that the price per share of IBM stock was $ 105.03 on August 17 , 2001 , and approximately $ 84.16 on July 8 , 2004 . On February 11 , 2004 , petitioners filed their 2001 joint Federal income tax return . Petitioners ...
Page 34
... Parties ' Treatment of the Transaction In the master agreement the parties characterize the transaction as a loan and characterize the IBM shares as collateral . However , on August 17 , 2001 , the day after it received the IBM stock ...
... Parties ' Treatment of the Transaction In the master agreement the parties characterize the transaction as a loan and characterize the IBM shares as collateral . However , on August 17 , 2001 , the day after it received the IBM stock ...
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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