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 26
... transferred 990 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 ...
... transferred 990 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 ...
Page 27
... transferred all the benefits and burdens of ownership of the stock to Derivium for $ 93,586.23 with no obligation to repay that amount . 2. Held , further , the transaction was not analogous to the securities lending arrangement in Rev ...
... transferred all the benefits and burdens of ownership of the stock to Derivium for $ 93,586.23 with no obligation to repay that amount . 2. Held , further , the transaction was not analogous to the securities lending arrangement in Rev ...
Page 28
... is merely for convenience in describing what petitioners contend the transaction represents . [ Petitioner ] understands that by transferring securities as collateral 28 888 ( 26 ) 135 UNITED STATES TAX COURT REPORTS.
... is merely for convenience in describing what petitioners contend the transaction represents . [ Petitioner ] understands that by transferring securities as collateral 28 888 ( 26 ) 135 UNITED STATES TAX COURT REPORTS.
Page 29
United States. Tax Court. [ Petitioner ] understands that by transferring securities as collateral to * * * [ Derivium ] ... transfer , pledge , repledge , hypothecate , rehypothecate , lend , short sell , and / or sell outright some or all ...
United States. Tax Court. [ Petitioner ] understands that by transferring securities as collateral to * * * [ Derivium ] ... transfer , pledge , repledge , hypothecate , rehypothecate , lend , short sell , and / or sell outright some or all ...
Page 30
... 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 the IBM stock transferred ...
... 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 the IBM stock transferred ...
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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