Reports of the United States Tax Court, Band 91United States Tax Court, 1989 |
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9th Cir AARK Acquired Banks activity addition to tax affd affg agreement amended amount apply assets capital Carlton cash claimed collateral estoppel Commissioner contract core deposits corporation costs debt decedent's December 31 defendant Meier deposit base distribution entitled equipment estate tax evidence expenses export facts fair market value Federal income tax fees filed funds futures contracts grand jury Hatsis held Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service investment investors issue lease liability litigation loan loss marital deduction notice of deficiency opinion paid parties partners payments percent petition petitioner petitioner's profit promissory note purchase pursuant qualified received record regulations respect respondent's share shareholders statute stipulated straddle substantial supra T.C. Memo Tax Court taxable taxpayer tion trade or business transactions transfers trial trust Tudor United Universal Life Church Urban
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Seite 1091 - The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under the method of accounting used in computing taxable income, such amount is to be properly accounted for as of a different period.
Seite 79 - This decision appears to fall in that small class which finally determine claims of right separable from, and collateral to, rights asserted in the action, too important to be denied review and too independent of the cause itself to require that appellate consideration be deferred until the whole case is adjudicated.
Seite 106 - ... no substantial part of the activities of which is carrying on propaganda, or otherwise attempting to influence legislation, and which does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of any candidate for public office.
Seite 333 - If his surviving spouse is entitled for life to all the Income from the entire interest, or all the income from a specific portion...
Seite 62 - B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders, par. 10.05 (5th ed. 1987). Petitioners...
Seite 790 - If a partner engages in a transaction with a partnership other than in his capacity as a member of such partnership, the transaction shall, except as otherwise provided in this section, be considered as occurring between the partnership and one who is not a partner.
Seite 106 - The amount of all bequests, legacies, devises, or transfers, to or for the use of the United States, any State, Territory, any political subdivision thereof, or the District of Columbia, for exclusively public purposes, or to or for the use of any corporation organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes...
Seite 341 - ... shall impose upon the person who signed it, a represented party, or both, an appropriate sanction, which may include an order to pay to the other party or parties the amount of the reasonable expenses incurred because of the filing of the pleading, motion, or other paper, including a reasonable attorney's fee.
Seite 67 - Where, upon the lapse of time, upon the occurrence of an event or contingency, or upon the failure of an event or contingency to occur...
Seite 51 - If the Board finds that there is no deficiency and further finds that the taxpayer has made an overpayment of tax in respect of the taxable year in respect of which the Commissioner determined the deficiency...