Reports of the Tax Court of the United States, Volum 109U.S. Government Printing Office, 1997 |
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Side 127
... answer asserting in the alternative that petitioner is liable for additions to tax pursuant to sections 6651 ( a ) ( 1 ) and 6653 ( a ) ( 1 ) and ( 2 ) . In our original bench opinion , we upheld respondent's defi- ciency determination ...
... answer asserting in the alternative that petitioner is liable for additions to tax pursuant to sections 6651 ( a ) ( 1 ) and 6653 ( a ) ( 1 ) and ( 2 ) . In our original bench opinion , we upheld respondent's defi- ciency determination ...
Side 194
... answered with certainty and a definite rule be prescribed . Frequently , the particular policy is comparatively immaterial , so long as the rule to be applied is known . The committee believes it to be impracticable to attempt by ...
... answered with certainty and a definite rule be prescribed . Frequently , the particular policy is comparatively immaterial , so long as the rule to be applied is known . The committee believes it to be impracticable to attempt by ...
Side 225
... answer the question of the validity of the regulation . Generally , temporary regulations are accorded the same weight as final regulations . Redlark v . Commissioner , 106 T.C. 31 , 38 ( 1996 ) ; Peterson Marital Trust v . Commissioner ...
... answer the question of the validity of the regulation . Generally , temporary regulations are accorded the same weight as final regulations . Redlark v . Commissioner , 106 T.C. 31 , 38 ( 1996 ) ; Peterson Marital Trust v . Commissioner ...
Side 241
... answer to raise the affirmative defense of collateral estoppel in this case was granted . Respondent now bears the burden of proving the applicability of that defense . Rule 142 ( a ) . The jurisdictional competency of this Court in ...
... answer to raise the affirmative defense of collateral estoppel in this case was granted . Respondent now bears the burden of proving the applicability of that defense . Rule 142 ( a ) . The jurisdictional competency of this Court in ...
Side 295
... answer filed on Oct. 21 , 1996. Re- spondent concedes that this issue is new matter under Rule 142 ( a ) . Thus , respondent has the burden of proving that the duty of consistency applies here . Rule 142 ( a ) ; see Cluck v . Commis ...
... answer filed on Oct. 21 , 1996. Re- spondent concedes that this issue is new matter under Rule 142 ( a ) . Thus , respondent has the burden of proving that the duty of consistency applies here . Rule 142 ( a ) ; see Cluck v . Commis ...
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Reports of the Tax Court of the United States, Volum 108 United States. Tax Court Uten tilgangsbegrensning - 1997 |
Reports of the Tax Court of the United States, Volum 7 United States. Tax Court Uten tilgangsbegrensning - 1947 |
Reports of the Tax Court of the United States, Volum 118 United States. Tax Court Uten tilgangsbegrensning - 2002 |
Vanlige uttrykk og setninger
1245 class property abate interest action administrative costs agreement Aldergrove Alumax board Alumax class Amax amount application assets basis BCCI Bowlen carryback claimed class C common Code Section Commissioner common stock corporation counsel decision declaratory judgment deduction deficiency deposition determination directors disputed property items easement Elbow Lake electrical failure to abate fair market value fees FERC filed fundraising funds housefile Howard County Income Tax Regs Internal Revenue Internal Revenue Service involved issue Jackson Hewitt JOINDER OF ISSUE July 30 ment Mitsui Mitsui group motion nonlife notice paragraph party payment percent peti petition petitioner petitioner's Petitioners contend player contracts pleading property unit purposes pursuant qualified relating requests for abatement respect respondent respondent's Rule section 1245 class stipulation stockholders structural components supra T.C. Memo Tax Court tax liability tax matters partner taxable taxpayer tion tioner VEBA trust voting power
Populære avsnitt
Side 586 - 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 586 - 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 378 - ... Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, 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, and which does not...
Side 307 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
Side 157 - As used in this chapter, the term "affiliated group" means one or more chains of includible corporations connected through stock ownership with a common parent corporation which is an includible corporation if— (1) Stork possessing at least 80 percent of the voting power of all classes of stock and at least 80 percent of each class of the nonvoting stock of each of the...
Side 543 - 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 654 - A subpoena may be served by the marshal, by his deputy, or by any other person who is not a party and is not less than 18 years of age. Service of a subpoena upon a person named therein shall be made by delivering a copy thereof to such person and by tendering to him the fees for one day's attendance and the mileage allowed by law.
Side 551 - Such amendment of the pleadings as may be necessary to cause them to conform to the evidence and to raise these issues may be made upon motion of any party at any time, even after judgment...
Side 654 - If service is made by a person other than a United States marshal or his deputy, he shall make affidavit thereof.
Side 606 - When a motion for summary judgment is made and supported as provided in this rule, an adverse party may not rest upon the mere allegations or denials of his pleading, but his response, by affidavits or as otherwise provided in this rule must set forth specific facts showing that there is a genuine issue for trial. If he does not so respond, summary judgment, if appropriate, shall be entered against him.