Reports of the United States Tax Court, Volume 98United States Tax Court, 1992 |
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9th Cir additions to tax affd alternative minimum tax amended amount apply assets bankruptcy Carlsbad property charitable claim collateral estoppel Commissioner Condor Congress contends contract corporation cost decedent decedent's deduction distribution election estate tax facts fair market value Federal income tax filed gift tax Government gross income Halliburton held Income Tax Regs income tax return industry interest Internal Revenue Code Internal Revenue Service issue jurisdiction legislative history loan marital deduction meaning of section method notice of deficiency obligation opinion Oregon paid parties partners partnership payments percent petition petitioner Petitioner argues petitioner's prior provides purchase purposes pursuant qualified reasonable receipt received regulations Rept res judicata respect Respondent argues Respondent determined respondent's Roseburg Rule settlement agreement Stat statute statutory summary judgment supra surviving spouse T.C. Memo Tax Court tax liability taxable income taxpayer term timber tion United Universale USVI Willard Robertson WQXI-AM
Popular passages
Page 401 - But where the second action between the same parties is upon a different claim or demand, the judgment in the prior action operates as an estoppel only as to those matters in issue or points controverted, upon the determination of which the finding or verdict was rendered. In all cases, therefore, where it is sought to apply the estoppel of a judgment rendered upon one cause of action to matters arising in a suit upon a different cause of action, the inquiry must always be as to the point or question...
Page 407 - It is a finality as to the claim or demand in controversy, concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand, but as to any other admissible matter which might have been offered for that purpose...
Page 599 - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...
Page 536 - renegotiation" Includes any transaction which Is a renegotiation within the meaning of the Federal renegotiation act applicable to such transaction, any modification of one or more contracts with the United States or any agency thereof, and any agreement with the United States or any agency thereof In respect of one or more such contracts or subcontracts thereunder. (B) The term "excessive profits...
Page 354 - The amount of all items of gross income in respect of a decedent which are not properly includible in respect of the taxable period in which falls the date of his death or a prior period...
Page 148 - If there is no plan but a method of employer contributions or compensation has the effect of a stock bonus, pension, profit-sharing, or annuity plan, or similar plan deferring the receipt of compensation, this paragraph shall apply as if there were such a plan.
Page 647 - The combined gross amount earned during the taxable year, from investment income and from underwriting income as provided in this subsection, computed on the basis of the underwriting and investment exhibit of the annual statement approved by the National Convention of Insurance Commissioners.
Page xx - Today marks my final roll call with you. But I want you to know that when I cross the river, my last conscious thoughts will be of The Corps, and The Corps, and The Corps.
Page 372 - Staff of the Joint Committee on Taxation indicates that the new regulations under § 706 are to be "comparable to prior law." Staff of the Joint Comm. on Taxation, General Explanation of the Revenue Provisions of the Deficit Reduction Act of 1984.
Page 405 - In which case the tax shall be computed on the aggregate Income, and the liability with respect to the tax shall be Joint and several.