Reports of the United States Tax Court, Volum 93United States Tax Court, 1989 |
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United States. Tax Court. OF THE UNITED STATES TAX COURT UNITED STATES TAX UIS COURT July 1 , 1989 , to December 31 , 1989 Volume 93 ( Cite 93 T.C. ) JOHN T. FEE REPORTER OF DECISIONS U.S. GOVERNMENT PRINTING OFFICE WASHINGTON : 1989 For ...
United States. Tax Court. OF THE UNITED STATES TAX COURT UNITED STATES TAX UIS COURT July 1 , 1989 , to December 31 , 1989 Volume 93 ( Cite 93 T.C. ) JOHN T. FEE REPORTER OF DECISIONS U.S. GOVERNMENT PRINTING OFFICE WASHINGTON : 1989 For ...
Side 10
United States. Tax Court. be granted under Rev. Proc . 65-17 . Petitioner , Manufactur- ing , Specialty , and respondent were all parties to the closing agreement . Closing agreements are no more than contracts , and are " governed by ...
United States. Tax Court. be granted under Rev. Proc . 65-17 . Petitioner , Manufactur- ing , Specialty , and respondent were all parties to the closing agreement . Closing agreements are no more than contracts , and are " governed by ...
Side 33
United States. Tax Court. nue Manual , section 5236 , calling for much more extensive inquiry to ascertain a ... United States , 853 F.2d 1209 , 1212 ( 5th Cir . 1988 ) ; United States v . Ahrens , 530 F.2d at 785 ; Frieling v ...
United States. Tax Court. nue Manual , section 5236 , calling for much more extensive inquiry to ascertain a ... United States , 853 F.2d 1209 , 1212 ( 5th Cir . 1988 ) ; United States v . Ahrens , 530 F.2d at 785 ; Frieling v ...
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 68
United States. Tax Court. issue for our decision is whether petitioner , the acquired corporation in a friendly takeover , may deduct under section 162 ( a ) 1 the expenditures it incurred incident to the takeover . FINDINGS OF FACT Most ...
United States. Tax Court. issue for our decision is whether petitioner , the acquired corporation in a friendly takeover , may deduct under section 162 ( a ) 1 the expenditures it incurred incident to the takeover . FINDINGS OF FACT Most ...
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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
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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...