Reports of the United States Tax Court, Volume 134United States Tax Court, 2010 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
From inside the book
Results 1-5 of 35
Page 26
... transfer of a portion of a nontaxable recovery that is nontaxable to the relator . Petitioner also cites Eisner v . Macomber , 252 U.S. 189 ( 1920 ) , for the definition of income . Macomber held that income was the " gain derived from ...
... transfer of a portion of a nontaxable recovery that is nontaxable to the relator . Petitioner also cites Eisner v . Macomber , 252 U.S. 189 ( 1920 ) , for the definition of income . Macomber held that income was the " gain derived from ...
Page 132
... transfer pricing of services under section 482 . 9 This regulation wasn't issued until 1996. T.D. 8707 , 1997–1 C.B. 128 . 10 The second is section 954 ( h ) , which defines a " lending or finance business " as the business of , among ...
... transfer pricing of services under section 482 . 9 This regulation wasn't issued until 1996. T.D. 8707 , 1997–1 C.B. 128 . 10 The second is section 954 ( h ) , which defines a " lending or finance business " as the business of , among ...
Page 133
... transfer - pricing situa- tions , the Commissioner has struggled . In General Counsel Memorandum ( GCM ) 38499 ( Sept. 19 , 1980 ) , 12 the Commissioner agreed with a proposed revenue ruling 13 concluding that the " guarantee of the ...
... transfer - pricing situa- tions , the Commissioner has struggled . In General Counsel Memorandum ( GCM ) 38499 ( Sept. 19 , 1980 ) , 12 the Commissioner agreed with a proposed revenue ruling 13 concluding that the " guarantee of the ...
Page 134
... ( including guarantees ) would otherwise be considered the provision of services for transfer pricing purposes . " Id . also stressed that our decision turned on a question of 134 ( 122 ) 134 UNITED STATES TAX COURT REPORTS.
... ( including guarantees ) would otherwise be considered the provision of services for transfer pricing purposes . " Id . also stressed that our decision turned on a question of 134 ( 122 ) 134 UNITED STATES TAX COURT REPORTS.
Page 135
... transfer - pricing context again . This time he reasoned that The Centel decision increases the litigating hazards * * * . However , we do not read this case as contradicting the position of the Service as estab- lished in * * * G.C.M. ...
... transfer - pricing context again . This time he reasoned that The Centel decision increases the litigating hazards * * * . However , we do not read this case as contradicting the position of the Service as estab- lished in * * * G.C.M. ...
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