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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Results 1-5 of 98
Page 26
... shares of IBM common stock to Derivium in exchange for $ 93,586.23 . The terms of the agree- ment characterized the transaction as a loan of 90 percent of the value of the IBM stock pledged as collateral . The pur- 5 Petitioner does not ...
... shares of IBM common stock to Derivium in exchange for $ 93,586.23 . The terms of the agree- ment characterized the transaction as a loan of 90 percent of the value of the IBM stock pledged as collateral . The pur- 5 Petitioner does not ...
Page 27
... shares of International Business Machines Corp. ( IBM ) common stock to Derivium Capital , L.L.C. ( Derivium ) , in exchange for $ 93,586.23 was a sale or a loan ; ( 2 ) whether the transaction qualifies as a securities lending ...
... shares of International Business Machines Corp. ( IBM ) common stock to Derivium Capital , L.L.C. ( Derivium ) , in exchange for $ 93,586.23 was a sale or a loan ; ( 2 ) whether the transaction qualifies as a securities lending ...
Page 28
... shares of IBM stock . During 2001 petitioner's financial adviser , Bert Falls , introduced him to Derivium and its 90 - percent - stock - loan program . 2 Under that program Derivium would purport to lend 90 percent of the value of ...
... shares of IBM stock . During 2001 petitioner's financial adviser , Bert Falls , introduced him to Derivium and its 90 - percent - stock - loan program . 2 Under that program Derivium would purport to lend 90 percent of the value of ...
Page 29
... shares of International Business Ma- chines Corporation ( IBM ) . $ 105,444.90 ( as of 8/6/01 , at $ 106.51 per share ) . 90 % of the market value on closing , in part or in whole . 10.50 % , compounded annually , accruing until and due ...
... shares of International Business Ma- chines Corporation ( IBM ) . $ 105,444.90 ( as of 8/6/01 , at $ 106.51 per share ) . 90 % of the market value on closing , in part or in whole . 10.50 % , compounded annually , accruing until and due ...
Page 30
... shares of IBM stock held in its Morgan Keegan account for $ 103,984.65 ( i.e. , $ 105.035 per share of IBM common stock ) . The net proceeds from Derivium's sale of the IBM stock were $ 103,918.18 ( i.e. , $ 103,984.65 minus a $ 3.47 ...
... shares of IBM stock held in its Morgan Keegan account for $ 103,984.65 ( i.e. , $ 105.035 per share of IBM common stock ) . The net proceeds from Derivium's sale of the IBM stock were $ 103,918.18 ( i.e. , $ 103,984.65 minus a $ 3.47 ...
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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