Reports of the Tax Court of the United States, Volume 92U.S. Government Printing Office, 1989 |
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Common terms and phrases
5th Cir addition to tax adjustment affd affg agreement amended American Bar Endowment American Greetings amount apply ARCO stock argues B&L Ireland CBOE claimed Commis Commissioner compensation Congress contributions corporation December 31 deductions Diamond distribution dividend Elco employee entitled estate tax evidence facts Federal income tax filed funds Hallmark held Hydron included Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service inventory investment issue Judge Judicial Plan jurisdiction lease lens mailed manufacturing market maker master recording molding process motion notice of deficiency NPDC opinion option paid parties partnership payment percent petition petitioner's petitioners premium profit purposes pursuant received reported respect respondent's retroactive rate credits Robotics royalty Rule shares sioner soft contact lenses spin cast statute statutory supra T.C. Memo Tax Court tax liability tax matters partner taxpayer testimony tion trade or business transaction United valuation
Popular passages
Page 573 - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 970 - 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 208 - That whenever in the opinion of the Commissioner the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income.
Page 670 - Government in criminal cases, factual findings resulting from an investigation made pursuant to authority granted by law, unless the sources of information or other circumstances indicate lack of trustworthiness.
Page 241 - At the request of a party the court shall order witnesses excluded so that they cannot hear the testimony of other witnesses, and it may make the order of its own motion. This rule does not authorize exclusion of (1) a party who is a natural person, or (2) an officer or employee of a party which is not a natural person designated as its representative by its attorney, or (3) a person whose presence is shown by a party to be essential to the presentation of the party's cause, or (4) a person authorized...
Page 811 - An economic interest is possessed in every case in which the taxpayer has acquired, by investment, any interest in mineral in place...
Page 870 - Under section 1031(a)(l), no gain or loss is recognized if property held for productive use in a trade or business or for investment...
Page 193 - Service performed by a duly ordained, commissioned, or licensed minister of a church in the exercise of his ministry or by a member of a religious order in the exercise of duties required by such order...
Page 986 - Losses from wagering transactions shall be allowed only to the extent of the gains from such transactions. (e) Theft losses. For purposes of subsection (a), any loss arising from theft shall be treated as sustained during the taxable year in which the taxpayer discovers such loss.
Page 885 - ... ordinary and necessary expenses paid or incurred for the production or collection of gross investment income or for the management, conservation, or maintenance of property held for the production of such income, determined with the modifications set forth in subparagraph (2) of this paragraph.