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 100
Page 11
... supra at 747 , the taxpayers attempted to sell the entire 13 - acre parcel on which their principal residence was situated , but they were able to sell only the dwelling and 3 acres surrounding the dwelling . Less than 1 year later ...
... supra at 747 , the taxpayers attempted to sell the entire 13 - acre parcel on which their principal residence was situated , but they were able to sell only the dwelling and 3 acres surrounding the dwelling . Less than 1 year later ...
Page 14
... supra at 245 . If a taxpayer assigns error to the Commissioner's deter- mination that the taxpayer is liable for the addition to tax , the Commissioner has the burden , under section 7491 ( c ) , of producing evidence to show that the ...
... supra at 245 . If a taxpayer assigns error to the Commissioner's deter- mination that the taxpayer is liable for the addition to tax , the Commissioner has the burden , under section 7491 ( c ) , of producing evidence to show that the ...
Page 34
... supra at 1237–1238 . Applying the above factors leads us to the conclusion that petitioner sold his IBM stock to Derivium in 2001 . ( 1 ) Whether Legal Title Passed On August 16 , 2001 , petitioner transferred the IBM stock to ...
... supra at 1237–1238 . Applying the above factors leads us to the conclusion that petitioner sold his IBM stock to Derivium in 2001 . ( 1 ) Whether Legal Title Passed On August 16 , 2001 , petitioner transferred the IBM stock to ...
Page 37
... supra at 1230. 10 Often it comes down to a question of substance over form requiring courts to " look beyond the parties ' terminology to the substance and economic reali- ties ' " . BB & T Corp. v . United States , 523 F.3d 461 , 476 ...
... supra at 1230. 10 Often it comes down to a question of substance over form requiring courts to " look beyond the parties ' terminology to the substance and economic reali- ties ' " . BB & T Corp. v . United States , 523 F.3d 461 , 476 ...
Page 42
... supra , the Internal Revenue Service was asked to determine whether the situation described above was a taxable disposition of stock by the stockholder . Petitioners urge this comparison because the revenue ruling concludes that there ...
... supra , the Internal Revenue Service was asked to determine whether the situation described above was a taxable disposition of stock by the stockholder . Petitioners urge this comparison because the revenue ruling concludes that there ...
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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