Reports of the Tax Court of the United States, Volume 102U.S. Government Printing Office, 1994 |
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Common terms and phrases
9th Cir addition to tax adjustment affd affg agree allocation amount applied arm's-length Ashland assets Blyth claims Clowery Commis Commissioner component computed corporation costs Court of Appeals deduction depletion determined drilling expenses facts Federal filed Flextronics FPAA gift tax gross income gross margin GST tax hydrogen sulfide Income Tax Regs intangibles Internal Revenue Internal Revenue Code Internal Revenue Service issue Kyocera manufacturing marital ment method notices of deficiency paid partnership payment percent percentage peti petition petitioner Petitioner contends petitioner's private letter ruling purchase purposes regulation resale reserve strengthening respect respondent respondent's royalty Rule Seagate Scotts Valley Seagate Singapore section 482 settlement agreement Singapore's spouse statute subscribers summary judgment supra T.C. Memo tax liability Tax Matters Partner tax returns taxable taxpayer third party tion tioner transactions transfer prices trust United Valley's
Popular passages
Page 428 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
Page 575 - ... Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not...
Page 679 - The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same provisions and limitations...
Page 387 - If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 6 years after the return was filed. For purposes of this subparagraph — (i) In the case of a trade or business, the term "gross income...
Page 103 - If no method of accounting has been regularly used by the taxpayer, or if the method used does not clearly reflect income, the computation of taxable income shall be made under such method as, in the opinion of the Secretary or his delegate, does clearly reflect income.
Page 404 - If teaching, research, or other services are required of all candidates (whether or not recipients of scholarships or fellowship grants) for a particular degree as a condition to receiving such degree, such teaching, research, or other services shall not be regarded as part-time employment within the meaning of this paragraph.
Page 39 - All expenditures made by an operator for wages, fuel, repairs, hauling, supplies, etc., incident to and necessary for the drilling of wells and the preparation of wells for the production of oil or gas...
Page 48 - ... (D) in the case of lead, zinc, copper, gold, silver, or fluorspar ores, potash, and ores which are not customarily sold in the form of the crude mineral product — crushing, grinding, and beneficiation by concentration (gravity, flotation; amalgamation, electrostatic, or magnetic), cyanidation, leaching, crystallization, precipitation (but not including...
Page 580 - An organization will be regarded as "operated exclusively" for one or more exempt purposes only if it engages primarily in activities which accomplish one or more of such exempt purposes specified in section 501 (c) (3).
Page 388 - The Board shall have jurisdiction to redetermine the correct amount of the deficiency even if the amount so redetermined is greater than the amount of the deficiency, notice of which has been mailed to the taxpayer, and to determine whether any penalty, additional amount or addition to the tax should be assessed — if claim therefor is asserted by the Commissioner at or before the hearing or a rehearing.