Reports of the United States Tax Court, Volume 135United States Tax Court, 2010 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
From inside the book
Results 6-10 of 30
Page 180
... street light assets . Respondent argues that the proper recovery period for those assets is 20 years ; in the alternative , he argues that it is 15 years . Petitioner argues that it is 7 years . We agree with petitioner . II . Statutory ...
... street light assets . Respondent argues that the proper recovery period for those assets is 20 years ; in the alternative , he argues that it is 15 years . Petitioner argues that it is 7 years . We agree with petitioner . II . Statutory ...
Page 181
... street light assets are “ pri- marily used " , see sec . 1.167 ( a ) –11 ( b ) ( 4 ) ( iii ) ( b ) , Income Tax Regs . , in the " distribution of electricity for sale " and so prop- erly classified under asset class 49.14 , see Rev ...
... street light assets are “ pri- marily used " , see sec . 1.167 ( a ) –11 ( b ) ( 4 ) ( iii ) ( b ) , Income Tax Regs . , in the " distribution of electricity for sale " and so prop- erly classified under asset class 49.14 , see Rev ...
Page 182
... street light assets fall within asset class 49.14 ; in the alternative , he argues that they fall within asset class 00.3 . Petitioner argues that they fall within neither . First , we find that street light assets are not used in the ...
... street light assets fall within asset class 49.14 ; in the alternative , he argues that they fall within asset class 00.3 . Petitioner argues that they fall within neither . First , we find that street light assets are not used in the ...
Page 183
... street and area lighting is an electric service and because " a distribution system will typically include all assets used to provide electric services " , street light assets are part of the distribution system . That argument relies ...
... street and area lighting is an electric service and because " a distribution system will typically include all assets used to provide electric services " , street light assets are part of the distribution system . That argument relies ...
Page 184
... Street light assets are distinct from distribution assets ; they have a different purpose and a different function . Moreover , street light assets can be disconnected from the distribution system without disturbing the distribution of ...
... Street light assets are distinct from distribution assets ; they have a different purpose and a different function . Moreover , street light assets can be disconnected from the distribution system without disturbing the distribution of ...
Other editions - View all
Common terms and phrases
accuracy-related penalty addition to tax adjustment allowance Appeals officer apply Appointments Clause assessment Caer's estate carryback CDP hearing Chesapeake claim Commissioner Congress corporation Court of Appeals Dalton deduction Derivium determination emphasis added equitable tolling estate tax Federal income tax filed forward contract gross income IBM stock Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue jurisdiction lake house lien loan loss ment notice of deficiency Ocean Pines Office of Appeals parties partner partnership item payment percent peti petition petitioner petitioner's principal residence provides purposes pursuant PVFCS refund regulations reported respect respondent's Rule schedule section 107 shares Stat statute street light assets supra T.C. Memo Tax Court tax imposed tax liability tax shown taxable taxpayer term Texasgulf tion tioner transaction transfer trust underpayment United Virgin Islands whistleblower windfall tax WISCO withholding credits