Reports of the Tax Court of the United States, Volume 86U.S. Government Printing Office, 1986 |
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Common terms and phrases
9th Cir activity affd agreement alternative minimum tax amount apply assets Barrow Brooksville cash CATV CATV system claimed Cofman Commissioner Comp-U-Med Comp-U-Med's contract corporation Court crude oil decedent decedent's December 31 deductions determined Digitax disallowed distribution Erickson expenses fact fair market value Federal income tax fees filed franchise gift tax gross income Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service investment investors issue Kuwait lease limited loss mineral minimum NIOC nonrecourse debt nonrecourse note Norwood notice of deficiency obligation operating organization paid parties partner partnership Paxton payment percent period petition petitioner petitioner's production profit promissory note purchase purposes pursuant received Reportco respect respondent respondent's royalty Rule Service sioner statute straddle sublicenses supra T.C. Memo tax liability taxable taxpayer terminals tion trade or business transaction transfer trust windfall profit tax
Popular passages
Page 125 - Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a): (1) CITIZENS AND DOMESTIC CORPORATIONS.— In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and (2) RESIDENT OF THE UNITED STATES OR PUERTO RICO.
Page 570 - 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 341 - An economic interest is possessed in every case in which the taxpayer has acquired by investment any interest in mineral in place or standing timber and secures, by any form of legal relationship, income derived from the extraction of the mineral or severance of the timber, to which he must look for a return of his capital.
Page 938 - ... in the year in which the taxes of the foreign country or the possession of the United States accrued, subject, however, to the conditions prescribed in subsection (c) of this section.
Page 570 - Except as provided in subsection (b), there shall be allowed as a deduction in computing taxable income all expenditures paid or incurred during the taxable year for the development of a mine or other natural deposit (other than an oil or gas well) if paid or incurred after the existence of ores or minerals in commercially marketable quantities has been disclosed.
Page 138 - If It were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain, If any, to the recipient shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property.
Page 480 - 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 xvii - The amount of the tax previously determined shall be the excess of — "(1) the sum of (A) the amount shown as the tax by the taxpayer upon his return (determined as provided in section 271 (b) (1) and (3) ), if a return was made by the taxpayer and an amount was shown as the tax by the taxpayer thereon, plus...
Page 351 - ... the language of the statute is broad enough to provide, at least, for every case in which the taxpayer has acquired, by investment, any interest in the oil in place, and secures, by any form of legal relationship, income derived from the extraction of the oil, to which he must look for a return of his capital.
Page 966 - An employees' trust (or under a contract purchased by an employees' trust) forming part of a pension, stock bonus, or profit-sharing plan which, at the time of the decedent's separation from employment (whether by death or otherwise), or at...