Reports of the United States Tax Court, Volum 93United States Tax Court, 1989 |
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Side 27
United States. Tax Court. The petition in this case was filed 349 days after the mailing of the notice of deficiency . OPINION In general , a taxpayer engages the deficiency jurisdiction of this Court by filing a petition for ...
United States. Tax Court. The petition in this case was filed 349 days after the mailing of the notice of deficiency . OPINION In general , a taxpayer engages the deficiency jurisdiction of this Court by filing a petition for ...
Side 52
United States. Tax Court. stated by the District Court in John Q. Shunk Association , Inc. v . United States , 626 F. Supp . 564 , 571 ( S. D. Ohio 1985 ) , in applying other provisions of section 4945 , while recognizing that " [ the ] ...
United States. Tax Court. stated by the District Court in John Q. Shunk Association , Inc. v . United States , 626 F. Supp . 564 , 571 ( S. D. Ohio 1985 ) , in applying other provisions of section 4945 , while recognizing that " [ the ] ...
Side 74
... Court ; a distribution of stock dividends , General Bancshares Corp. v . Commissioner , supra ; a recapitalization , Mills Estate Inc. v . Commissioner , supra ; a corporate reorganization , Gravois Planing Mill Co. v . Commissioner ...
... Court ; a distribution of stock dividends , General Bancshares Corp. v . Commissioner , supra ; a recapitalization , Mills Estate Inc. v . Commissioner , supra ; a corporate reorganization , Gravois Planing Mill Co. v . Commissioner ...
Side 107
United States. Tax Court. services rendered by the taxpayer . " Respondent contends , and we agree , that the record does not disclose any personal services rendered by Mrs. Gord ; therefore we cannot make any allocation between income ...
United States. Tax Court. services rendered by the taxpayer . " Respondent contends , and we agree , that the record does not disclose any personal services rendered by Mrs. Gord ; therefore we cannot make any allocation between income ...
Side 133
United States. Tax Court. the payment is absorbed . " Rev. Rul . 73-305 , 1973-2 C.B. 43 ; see also Rev. Proc . 84-58 , 1984-2 C.B. 501 , 503. In the case before us , respondent did not adhere to the enunciated rule . The statement of ...
United States. Tax Court. the payment is absorbed . " Rev. Rul . 73-305 , 1973-2 C.B. 43 ; see also Rev. Proc . 84-58 , 1984-2 C.B. 501 , 503. In the case before us , respondent did not adhere to the enunciated rule . The statement of ...
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5th Cir action additions to tax administrative affd agreement alternative minimum tax amendments are effective amount Angola application assessment assets Belk charitable claimed Code Section Commis Commissioner corporation counsel decedent December 31 declaratory judgment deduction deposition determined distribution employees estate tax expenses fact fair market value farm filed FPAA gift tax gross estate held Income Tax Regs income tax return inter vivos trust interest Internal Revenue Code Internal Revenue Service inventory Iran issue July Krock loan loss method of accounting motion notice of deficiency paid paragraph partnership party payment percent period person petition petitioner petitioner's preferred stock premium prior punitive damages purchase purposes pursuant qualified reasonable received references reinsurance reported request respect respondent's Rule shareholders shares sioner statute stipulation supra surviving spouse T.C. Memo Tax Court taxable taxpayer tion transaction transfer trial trust United valuation
Populære avsnitt
Side 493 - ... or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation...
Side 920 - Use of depositions. — At the trial or upon the hearing of a motion or an interlocutory proceeding, any part or all of a deposition, so far as admissible under the rules of evidence applied as though the witness were then present and testifying...
Side 920 - If the deposition is not signed by the witness, the officer shall sign it and state on the record the fact of the waiver or of the illness or absence of the witness or the fact of the refusal to sign together with the reason, if any, given therefor; and the deposition may then be used as fully as though signed, unless...
Side 869 - If he is without knowledge or information sufficient to form a belief as to the truth of an averment, he shall so state and this has the effect of a denial.
Side 941 - Supporting and opposing affidavits shall be made on personal knowledge, shall set forth such facts as would be admissible in evidence, and shall show affirmatively that the affiant is competent to testify to the matters stated therein.
Side 96 - ... bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.
Side 900 - ... it is a sufficient answer to such interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries.
Side 384 - Plaintiff Sierra Club is a non-profit corporation organized and operating under the laws of the State of California, with its principal place of business in San Francisco, California since 1892.
Side 862 - In the complaint the title of the action shall include the names of all the parties, but in other pleadings it is sufficient to state the name of the first party on each side with an appropriate indication of other parties.
Side 240 - The taxable year in which the property is placed in a condition or state of readiness and availability for a specifically assigned function...