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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Page 199
... partnership . W contributed approximately two - thirds of the LLC's total assets in 1999 in exchange for a 5 - percent interest in the LLC and a special distribution of cash . W used a portion of the cash to make a loan to P in return ...
... partnership . W contributed approximately two - thirds of the LLC's total assets in 1999 in exchange for a 5 - percent interest in the LLC and a special distribution of cash . W used a portion of the cash to make a loan to P in return ...
Page 203
... partnership structure required WISCO to first transfer its tissue business assets to a joint venture . GP would then ... partnership struc- ture as tax advantageous to Chesapeake because it would allow Chesapeake to get cash out of the ...
... partnership structure required WISCO to first transfer its tissue business assets to a joint venture . GP would then ... partnership struc- ture as tax advantageous to Chesapeake because it would allow Chesapeake to get cash out of the ...
Page 204
... partnership struc- ture to expand its tissue business . GP did not have any interest in Chesapeake receiving a tax deferral . GP recog- nized , however , that it was a necessary part of bridging the purchase price gap . Chesapeake ...
... partnership struc- ture to expand its tissue business . GP did not have any interest in Chesapeake receiving a tax deferral . GP recog- nized , however , that it was a necessary part of bridging the purchase price gap . Chesapeake ...
Page 205
... partnership for tax purposes , ( 2 ) whether WISCO was a partner in the joint venture , and ( 3 ) whether the distribu- 7 We use the terms " partners , " " partnership , " and " LLC " for narrative convenience only as these are the ...
... partnership for tax purposes , ( 2 ) whether WISCO was a partner in the joint venture , and ( 3 ) whether the distribu- 7 We use the terms " partners , " " partnership , " and " LLC " for narrative convenience only as these are the ...
Page 206
... partnership interest . Mr. Miller advised that WISCO maintain assets of at least 20 percent of its maximum exposure ... partnership and is expected to continue to equal at least 10 percent throughout the life of the partnership ...
... partnership interest . Mr. Miller advised that WISCO maintain assets of at least 20 percent of its maximum exposure ... partnership and is expected to continue to equal at least 10 percent throughout the life of the partnership ...
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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