Reports of the United States Tax Court, Volum 90United States Tax Court, 1988 |
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2d Cir 5th Cir addition to tax affd agree agreement amended amount Amway apply argues assets basis bonds Brewery Workers Fund Calzone capital cash claimed Commissioner contract corporation costs debt decedent decedent's December 31 deduction depreciation distribution equipment estate tax facts Federal income tax filed film Goodbody grand jury gross receipts held Hughes Supply hydrogen sulfide Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue Lake Havasu gold lease lenders liability loss marital deduction ment merger Merrill Lynch mortgage loans motion picture Normac notice of deficiency opinion overpasses paid parties partnership payments percent Persky-Bright petition petitioner petitioner's prior production profit purchase pursuant received regulations respect respondent's rule 6(e shareholder sioner stipulated supra T.C. Memo Tax Court taxable taxpayer Teamsters Fund tion transactions Transtech Trust United Vitagram Wenles windfall profit tax Winter Dreams
Populære avsnitt
Side 823 - An order that the matters regarding which the order was made or any other designated facts shall be taken to be established for the purposes of the action in accordance with the claim of the party obtaining the order...
Side 728 - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
Side 197 - The legal right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid them, by means which the law permits, cannot be doubted.
Side 543 - However, if property used in a trade or business or held for the production of income...
Side 607 - We cannot too often reiterate that 'taxation is not so much concerned with the refinements of title as it is with actual command over the property taxed — the actual benefit for which the tax is paid.
Side 821 - In lieu of any order or in addition thereto, the court shall require the party failing to act or the attorney advising him or both to pay the reasonable expenses, including attorney's fees, caused by the failure, unless the court finds that the failure was substantially justified or that other circumstances make an award of expenses unjust.
Side 155 - If the legatee, devisee, donee, or trustee is empowered to divert the property or fund, in whole or in part, to a use or purpose which would have rendered it, to the extent that it is subject to such power, not deductible had it been directly so bequeathed, devised, or given by the decedent, the deduction will be limited to that portion, if any. of the property or fund which is exempt from an exercise of the power.
Side 392 - Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property ; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income...
Side 501 - ... (b) EFFECTIVE DATE. — The amendment made by subsection (a) shall apply to taxable years beginning after December 31, 1963.
Side 101 - Any instance in which the value of any property, or the adjusted basis of any property, claimed on a return is 150 percent or more of the amount determined to be the correct amount of such valuation or adjusted basis...