Reports of the Tax Court of the United States, Volume 100U.S. Government Printing Office, 1993 |
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Common terms and phrases
6th Cir addition to tax affd affg agree amended amount apply appraisal argues award beneficiaries benefits Bob Jones University Cavenaugh Circuit claim Commis Commissioner Congress Court of Appeals currency swap damages received debenture decedent decedent's estate decision DISC disclaimer docket employees estate tax fact Federal estate tax Federal income tax filed gross income gross receipts Hagaman Halliburton hedging HISC included Income Tax Regs income tax return interest Internal Revenue Code issue judicial estoppel lease marital deduction memorial trust ment notice of deficiency opinion paid partial termination participants parties partnership percent personal injury peti petition petitioner petitioner's provides punitive damages purposes pursuant put options regulations Rept respondent's Rule Shawnee County SMIL Stat statute statutory summary judgment supra Supreme Court T.C. Memo Tax Court tax liability taxable taxpayer thermal airships tion tioner tort transaction transfer transferee liability transferor trust agreement United
Popular passages
Page 563 - 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 649 - If the taxpayer is unable to make his own return, the return shall be made by a duly authorized agent or by the guardian or other person charged with the care of the person or property of such taxpayer.
Page 617 - States, or (2) from the sale of personal property produced (in whole or in part) by the taxpayer within and sold without the United States, or produced (in whole or in part) by the taxpayer without and sold within the United States, shall be treated as derived partly from sources within and partly from sources without the United States.
Page 35 - Those directions which are not of the essence of the thing to be done, but which are given with a view merely to the proper, orderly and prompt conduct of the business, and by a failure to obey which the rights of those interested will not be prejudiced, are not commonly to be regarded as mandatory...
Page 528 - SEC. 162. Trade or business expenses— (a) In general. There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred...
Page 614 - States, there shall be deducted (for the purpose of computing the taxable income therefrom) the expenses, losses, and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income.
Page 201 - A check or other draft does not of itself operate as an assignment of any funds in the hands of the drawee available for its payment, and the drawee is not liable on the instrument until he accepts it.
Page 563 - Accounts or notes receivable acquired in the ordinary course of trade or business for services rendered...
Page 617 - The remainder, if any, shall be included in full as net income from sources within the United States. In the case of gross income derived from sources partly within and partly without the United States...
Page 192 - ... the last day prescribed for filing the return under section 6012 for such taxable year (determined without regard to any extension of time for filing such return).