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 40
... respect to Derivium , a magistrate judge for the Dis- trict Court for the Northern District of California rec- ommended that " injunctive relief against Derivium is ' nec- essary or appropriate for the enforcement of the Internal ...
... respect to Derivium , a magistrate judge for the Dis- trict Court for the Northern District of California rec- ommended that " injunctive relief against Derivium is ' nec- essary or appropriate for the enforcement of the Internal ...
Page 46
... respect to such portion . See sec . 6664 ( c ) ( 1 ) ; Higbee v . Commissioner , supra at 448. The determination of whether a taxpayer acted with reasonable cause and in good faith is made on a case - by - case basis , taking into ...
... respect to such portion . See sec . 6664 ( c ) ( 1 ) ; Higbee v . Commissioner , supra at 448. The determination of whether a taxpayer acted with reasonable cause and in good faith is made on a case - by - case basis , taking into ...
Page 49
... respect to the first question . Shares of stock of the same class are fungible , and this has given rise to apparently formalistic rules for determining questions of ownership ( and , by extension , disposition ) of such shares . The ...
... respect to the first question . Shares of stock of the same class are fungible , and this has given rise to apparently formalistic rules for determining questions of ownership ( and , by extension , disposition ) of such shares . The ...
Page 70
... respect his own characterization of the transaction as a loan ) . But unless future courts treat our analysis today as a limited - time ticket good only on Derivium cases , we may be creating more prob- lems than we're solving . WILLIAM ...
... respect his own characterization of the transaction as a loan ) . But unless future courts treat our analysis today as a limited - time ticket good only on Derivium cases , we may be creating more prob- lems than we're solving . WILLIAM ...
Page 77
... respect to such matter ) . ( 5 ) APPLICATION OF THIS SUBSECTION . — This subsection shall apply with respect to any action- ( A ) against any taxpayer , but in the case of any individual , only if such individual's gross income exceeds ...
... respect to such matter ) . ( 5 ) APPLICATION OF THIS SUBSECTION . — This subsection shall apply with respect to any action- ( A ) against any taxpayer , but in the case of any individual , only if such individual's gross income exceeds ...
Other editions - View all
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