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 33
Page 27
... securities lending arrangement in Rev. Rul . 57-451 , 1957-2 C.B. 295 , nor was it equivalent to a securities lending arrangement under sec . 1058 , I.R.C. 3. Held , further , Ps are liable for an addition to tax under sec . 6651 ( a ) ...
... securities lending arrangement in Rev. Rul . 57-451 , 1957-2 C.B. 295 , nor was it equivalent to a securities lending arrangement under sec . 1058 , I.R.C. 3. Held , further , Ps are liable for an addition to tax under sec . 6651 ( a ) ...
Page 28
... securities pledged to Derivium as collateral . Derivium was not registered with the New York Stock Exchange or the National Association of Securities Dealers / Financial Industry Regulatory Authority . Charles D. Cathcart was president ...
... securities pledged to Derivium as collateral . Derivium was not registered with the New York Stock Exchange or the National Association of Securities Dealers / Financial Industry Regulatory Authority . Charles D. Cathcart was president ...
Page 29
... securities during the period covered by the loan . *** [ Petitioner ] understands that * * * [ Derivium ] has the ... securities at the time of the renewal or refinancing , as follows : Large Caps at 4.5 % , Mid Caps at 5.5 % , Small ...
... securities during the period covered by the loan . *** [ Petitioner ] understands that * * * [ Derivium ] has the ... securities at the time of the renewal or refinancing , as follows : Large Caps at 4.5 % , Mid Caps at 5.5 % , Small ...
Page 30
... Securities , Inc. , to transfer 990 shares of IBM common stock ( IBM stock or collateral ) to Morgan Keegan & Co. ( Morgan Keegan ) and to credit Derivium's account . On August 16 , 2001 , Morgan Keegan credited Derivium's account with ...
... Securities , Inc. , to transfer 990 shares of IBM common stock ( IBM stock or collateral ) to Morgan Keegan & Co. ( Morgan Keegan ) and to credit Derivium's account . On August 16 , 2001 , Morgan Keegan credited Derivium's account with ...
Page 36
... securities during the period covered by the loan . *** [ Petitioner ] understands that *** [ Derivium ] has the right to receive and retain the benefits from any such transactions and that ** * [ petitioner ] is not entitled to these ...
... securities during the period covered by the loan . *** [ Petitioner ] understands that *** [ Derivium ] has the right to receive and retain the benefits from any such transactions and that ** * [ petitioner ] is not entitled to these ...
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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