Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 51
Page 96
... foreign corporation whose only substantial asset is unimproved land in the United States . On its 1994 , 1995 , and 1996 Federal income tax returns , P recognized rent and option income and claimed deductions for taxes and licenses ...
... foreign corporation whose only substantial asset is unimproved land in the United States . On its 1994 , 1995 , and 1996 Federal income tax returns , P recognized rent and option income and claimed deductions for taxes and licenses ...
Page 98
... foreign cor- poration file a true and accurate return " in the manner pre- scribed in this title " and rejected respondent's argument that the word " manner " , as it appeared in the quoted text , meant that the foreign corporation ...
... foreign cor- poration file a true and accurate return " in the manner pre- scribed in this title " and rejected respondent's argument that the word " manner " , as it appeared in the quoted text , meant that the foreign corporation ...
Page 99
... foreign corporation file its return timely in order to deduct its expenses . The Secretary made no mention of the consistent interpretation of the relevant text by the Court of Appeals for the Fourth Circuit and the Board not to include ...
... foreign corporation file its return timely in order to deduct its expenses . The Secretary made no mention of the consistent interpretation of the relevant text by the Court of Appeals for the Fourth Circuit and the Board not to include ...
Page 100
... Foreign Corporation , on the basis of a fiscal year ending on May 31. Its sole activity during the subject years was owning 160 acres of unimproved real estate ( U.S. real estate ) in San Diego County , California , and receiving option ...
... Foreign Corporation , on the basis of a fiscal year ending on May 31. Its sole activity during the subject years was owning 160 acres of unimproved real estate ( U.S. real estate ) in San Diego County , California , and receiving option ...
Page 103
... foreign corporation's deducting its expenses . Petitioner argues that it meets those requirements in that it filed true and accurate Federal income tax returns . According to petitioner , section 882 ( c ) ( 2 ) does not require that ...
... foreign corporation's deducting its expenses . Petitioner argues that it meets those requirements in that it filed true and accurate Federal income tax returns . According to petitioner , section 882 ( c ) ( 2 ) does not require that ...
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Common terms and phrases
9th Cir adjustments Admin administrative affd amended amount Anglo-Am Antarctica Appeals officer apply assessment Brand X capital loss Chevron claim closing agreement coal Commis Commissioner community property laws computation Congress conservation easement Court of Appeals December 31 deficiency notice Direct Tea Trading disputed regulations election entitled Fairfax County Federal income tax Federal tax foreign corporation GATT rate Grist Mill property gross income hearing Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service interpretation issue jurisdiction Lee Ranch legislative history levy LIFO limited majority mark-to-market ment method of accounting Natl notice of determination ous payment 99.00 overpayment interest parties petition petitioner petitioner's Planegger Proced provides real property reasonable refund relevant text relief Rept request respondent respondent's Revenue Act rule Secretary section 233 sioner spouse Stat statute statutory Subsequent miscellane supply contracts supra T.C. Memo Tax Court tax lien taxpayer tion United Zapara