Reports of the United States Tax Court, Volume 106The Court, 1996 - Government publications |
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Results 1-5 of 11
Page 313
... Intergraph conducted most of its business through foreign subsidiaries . Intergraph and its U.S. - based affiliated companies used the U.S. dollar as its functional currency . On May 14 , 1985 , Intergraph in Japan organized Nihon ...
... Intergraph conducted most of its business through foreign subsidiaries . Intergraph and its U.S. - based affiliated companies used the U.S. dollar as its functional currency . On May 14 , 1985 , Intergraph in Japan organized Nihon ...
Page 314
United States. Tax Court. Atlanta ) . Nihon Intergraph's banking relationship was main- tained primarily through Citibank , N.A.3 On June 7 , 1985 , representatives of Nihon Intergraph entered into an overdraft agreement ( overdraft ...
United States. Tax Court. Atlanta ) . Nihon Intergraph's banking relationship was main- tained primarily through Citibank , N.A.3 On June 7 , 1985 , representatives of Nihon Intergraph entered into an overdraft agreement ( overdraft ...
Page 315
... Nihon Intergraph in the total cumulative amount of ¥ 151,657,808 were deposited into Nihon Intergraph's checking account at Citibank Tokyo , thereby reducing the balance of Nihon Intergraph's overdraft amount . In essence , the ...
... Nihon Intergraph in the total cumulative amount of ¥ 151,657,808 were deposited into Nihon Intergraph's checking account at Citibank Tokyo , thereby reducing the balance of Nihon Intergraph's overdraft amount . In essence , the ...
Page 316
... Nihon Intergraph to Japanese tax and regulatory authorities as a debt obligation of Nihon Intergraph to Citibank Tokyo . For 1985 , the overdraft amount was reported by Intergraph on Form 5471 ( Information Return with Respect to a ...
... Nihon Intergraph to Japanese tax and regulatory authorities as a debt obligation of Nihon Intergraph to Citibank Tokyo . For 1985 , the overdraft amount was reported by Intergraph on Form 5471 ( Information Return with Respect to a ...
Page 317
... Nihon Intergraph's checking account at Citibank Tokyo . As a result , the ¥ 823,943,385 debit balance of Nihon Intergraph's check- ing account was reduced ... Intergraph's intercompany ( 312 ) 317 INTERGRAPH CORP . & SUBS . v . COMMISSIONER.
... Nihon Intergraph's checking account at Citibank Tokyo . As a result , the ¥ 823,943,385 debit balance of Nihon Intergraph's check- ing account was reduced ... Intergraph's intercompany ( 312 ) 317 INTERGRAPH CORP . & SUBS . v . COMMISSIONER.
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1989 agreement 9th Cir affd allocable alternative minimum tax amended apply Arkla assets benefits business expense cardholder CBOT Citibank cluster home Commis Commissioner Congress contract corporation cost Court of Appeals debt decedent decedent's deduction determined election employees estate tax executor Federal income tax filed funds gross income Guardian Income Tax Regs Internal Revenue Code investment Irwindale issue litigation loan Los Angeles Raiders Malibu marital deduction MasterCard meals ment Mexican pesos Nihon Intergraph obligation overdraft amount paid parties payment percent peti petitioner Petitioner argues petitioner's possession product purchase purposes pursuant QTIP Raiders received refund regulations reinsurance reinsurance agreement Rept respondent's rule statute summary judgment supra surviving spouse T.C. Memo tax avoidance Tax Court tax deficiencies tax return taxable income taxpayer Temporary Income Tax terminable interest tion tioner trade or business transaction transfer fees trust United VEBA