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 35
... Pay The master agreement obligates petitioner to transfer the IBM stock to Derivium and Derivium to pay 90 percent of the fair market value of the stock . The amount Derivium had to pay was determined after Derivium sold the IBM stock ...
... Pay The master agreement obligates petitioner to transfer the IBM stock to Derivium and Derivium to pay 90 percent of the fair market value of the stock . The amount Derivium had to pay was determined after Derivium sold the IBM stock ...
Page 36
... Payment of Property Taxes This factor is inapplicable under the facts of this case . ( 7 ) The Risk of Loss or Damage Upon receipt of the $ 93,586.23 from Derivium in 2001 , petitioner bore no risk of loss in the event that the value of ...
... Payment of Property Taxes This factor is inapplicable under the facts of this case . ( 7 ) The Risk of Loss or Damage Upon receipt of the $ 93,586.23 from Derivium in 2001 , petitioner bore no risk of loss in the event that the value of ...
Page 38
... pay principal or interest to Derivium , and it would have made no sense to do so unless the value of the stock had ... payment of tax on the gain . After the transfer petitioners did not conduct them- selves as if the transaction was a ...
... pay principal or interest to Derivium , and it would have made no sense to do so unless the value of the stock had ... payment of tax on the gain . After the transfer petitioners did not conduct them- selves as if the transaction was a ...
Page 61
... pay principal or interest to Derivium , and it would have made no sense to do so unless the value of the stock had substantially appreciated . " Majority op . p . 38 . That's way too broad a statement of the law if taken seri- ously ...
... pay principal or interest to Derivium , and it would have made no sense to do so unless the value of the stock had substantially appreciated . " Majority op . p . 38 . That's way too broad a statement of the law if taken seri- ously ...
Page 62
... Pay for Stocks " , http://www.sec.gov/investor/pubs/ margin.htm ; see also supra note 4. And the majority's holding ... payment otherwise would have been a cash dis- tribution to them , the Atwoods were charged with income when the loan ...
... Pay for Stocks " , http://www.sec.gov/investor/pubs/ margin.htm ; see also supra note 4. And the majority's holding ... payment otherwise would have been a cash dis- tribution to them , the Atwoods were charged with income when the loan ...
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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