Reports of the United States Tax Court, Volume 85United States Tax Court, 1986 |
Other editions - View all
Common terms and phrases
9th Cir activity affd affg agreement amount applied appraisal Ardsley assets atrazine basis cash claimed Commissioner contract corporation cost cotton cyanuric chloride December December 31 deduction depreciation Derbes distributorship Docket donated employee estate tax exempt expenses facts fair market value Federal income tax fees FHLMC filed films follows forward contracts Geigy-Basle GNMA gouaches gross income herbicides Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service inventory investment issue liability license lithographs LMEI/LMEC loss Molsen Monterey Pines Monterey Pines Investors motion nonrecourse notice of deficiency opinion overpayment Paccar Paccint paid parties partnership payments percent petition petitioner petitioner's profit purchase purposes pursuant record respect respondent's royalty Rule SAJAC sell simazine sold substantial supra T.C. Memo Tax Court taxable taxpayer tion TireSaver transactions transfer triazine trust United World Realty
Popular passages
Page 444 - The most stringent protection of free speech would not protect a man in falsely shouting fire in a theatre and causing a panic.
Page 444 - The question in every case is whether the words used are used in such circumstances and are of such a nature as to create a clear and present danger that they will bring about the substantive evils that Congress has a right to prevent.
Page 917 - ... that a trade secret or other confidential research, development, or commercial information not be disclosed or be disclosed only in a designated way; (8) that the parties simultaneously file specified documents or information enclosed in sealed envelopes to be opened as directed by the court.
Page 926 - The proceedings of the Tax Court and its divisions shall be conducted in accordance with such rules of practice and procedure (other than rules of evidence) as the Tax Court may prescribe and in accordance with the rules of evidence applicable in trials without a jury in the United States District Court of the District of Columbia.
Page 540 - Where before the expiration of the time prescribed in section 275 for the assessment of the tax, both the Commissioner and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.
Page 1132 - In lieu of any order or in addition thereto, the court shall require the party failing to act or the attorney advising him or both to pay the reasonable expenses, including attorney's fees, caused by the failure, unless the court finds that the failure was substantially justified or that other circumstances make an award of expenses unjust.
Page 533 - No suit or proceeding shall be maintained in any court for the recovery of any internal revenue tax alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected without authority, or of any sum alleged to have been excessive or in any manner wrongfully collected...
Page 612 - Issued, and if substantially all such stock (other than nonvoting preferred stock, the owners of which are not entitled or permitted to participate, directly or indirectly in the profits of the association, upon dissolution or otherwise, beyond the fixed dividends) is owned by producers who market their products or purchase the'ir supplies and equipment through the association...
Page 370 - All agreements for pecuniary considerations to control the business operations of the government, or the regular administration of justice, or the appointments to public offices, or the ordinary course of legislation, are void as against public policy, without reference to the question whether improper means are contemplated or used in their execution. The law looks to the general tendency of such agreements, and it closes the door to temptation by refusing them recognition in any of the courts of...
Page 501 - Under an accrual method of accounting, income is includible in gross income when all the events have occurred which fix the right to receive such income and the amount thereof can be determined with reasonable accuracy.