Reports of the Tax Court of the United States, Volume 97U.S. Government Printing Office, 1991 |
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Common terms and phrases
3d Cir 5th Cir additions to tax ADEA affd agreement airplane allocated alternative minimum tax amended amount apply assessment assets beneficiaries Butler County carryback Cheer bank claim combined taxable income Commis Commissioner computation Congress contract core deposit intangible Corp corporation cost decedent decedent's deduction deposit core depreciation DISC distribution employee ERISA ESOP estate tax exclusionary rule Federal income tax filed gross income Income Tax Regs income tax returns Intel interest Internal Revenue Code Internal Revenue Service inventory issue jurisdiction Levitt LIFO limited liquidated damages method notice of deficiency operating loss opinion paid parties partnership payment percent period petition petitioner Petitioner argues petitioner's prohibited transaction purchased purposes pursuant qualified received refund regulations Rept respect respondent's Retlaw rule shareholders silver waste sioner stare decisis Stat statute statutory supra T.C. Memo Tax Court taxpayer tion trust United Vandom
Popular passages
Page 354 - To sustain the privilege, it need only be evident from the implications of the question, in the setting in which it is asked, that a responsive answer to the question or an explanation of why it cannot be answered might be dangerous because injurious disclosure could result.
Page 313 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business) , but does not include stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Page 152 - It shall be an unlawful employment practice for an employer— (1) to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's race, color, religion, sex, or national origin...
Page 194 - To examine any books, papers, records, or other data which may be relevant or material...
Page 157 - ... amounts received, through accident or health insurance or under workmen's compensation acts, as compensation for personal injuries or sickness, plus the amount of any damages received whether by suit or agreement...
Page 699 - As used in this title in respect of a tax imposed by this title the term "deficiency" means — (1) The amount by which the tax imposed by this title exceeds the amount shown as the tax by the taxpayer upon his return...
Page 675 - ... ordinary and necessary expenses paid or incurred in carrying on a trade or business.
Page 252 - Property was acquired by a shareholder in the liquidation of a corporation in cancellation or redemption of stock, and (2) With respect to such acquisition — (A) Gain was realized, but (B) As the result of an election made by the shareholder under section 333, the extent to which gain was recognized was determined under section 333, then the basis shall be the same as the basis of such stock cancelled or redeemed in the liquidation, decreased in the amount of any money received by the shareholder,...
Page 698 - deficiency" means the amount by which the tax imposed by subtitles A or B exceeds the excess of — (1) The sum of (A) The amount shown as the tax by the taxpayer upon his return, if a return was made by the taxpayer...
Page 49 - Treasury regulations and interpretations long continued without substantial change, applying to unamended or substantially re-enacted statutes, are deemed to have received congressional approval, and have the effect of law.