Reports of the United States Tax Court, Volume 80United States Tax Court, 1983 - Government publications |
From inside the book
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Page 49
... agree upon among themselves . The partnership agreement further provided that contribu- tions to the capital of the partnership were to be made one - half by Jack Foster and one - sixth by each of his sons , and that profits and losses ...
... agree upon among themselves . The partnership agreement further provided that contribu- tions to the capital of the partnership were to be made one - half by Jack Foster and one - sixth by each of his sons , and that profits and losses ...
Page 50
... agreement to provide for their equal participation in the profits and losses resulting from the operation of the ... agreement were made at a time when the Fosters were actively assessing the feasibility of developing Foster City . The ...
... agreement to provide for their equal participation in the profits and losses resulting from the operation of the ... agreement were made at a time when the Fosters were actively assessing the feasibility of developing Foster City . The ...
Page 85
... agreement were not subsequently reduced to writing . As in previous dealings between the Fosters and the bank , negotiations were concluded and terms agreed upon by handshake . On August 19 , 1960 , Jack Foster purchased Brewer's Island ...
... agreement were not subsequently reduced to writing . As in previous dealings between the Fosters and the bank , negotiations were concluded and terms agreed upon by handshake . On August 19 , 1960 , Jack Foster purchased Brewer's Island ...
Page 97
... agreement was executed . Under its terms , Esteroy agreed not to permit its own liquidation unless and until the Fosters ... agree to renew the $ 2 million note to August 19 , 1967. By that time , however , the partnership's financial ...
... agreement was executed . Under its terms , Esteroy agreed not to permit its own liquidation unless and until the Fosters ... agree to renew the $ 2 million note to August 19 , 1967. By that time , however , the partnership's financial ...
Page 100
... Agreement of Release " with Republic and the Howard Corp. Under the terms of that agreement , the Fosters were released from personal liability for the Westway notes , which were assumed by Centex . In exchange therefor , the Fosters ...
... Agreement of Release " with Republic and the Howard Corp. Under the terms of that agreement , the Fosters were released from personal liability for the Westway notes , which were assumed by Centex . In exchange therefor , the Fosters ...
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Common terms and phrases
9th Cir acquired adjustment affd agreement allocation Alps Corp amount application assets basis benefit bonding bonus Brewer's Island capital carryback cash claimed Commissioner contract corporation Court debt decedent deduction depreciation disallowed distribution district docket earnings escrow Estero exchange exemption expenses fact fair market value Federal income tax filed fiscal Foster City Foster partnership gift tax GRFF gross income held Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service investment issue Jack Foster Kroger land lease Levon Records liability loan master recordings Neighborhood nonrecourse notice of deficiency operating loss paid parties partners payments percent petitioner petitioner's prior profits purposes pursuant qualified real property received reinsurance rent rental Rept respondent's rule section 482 shareholders shares specific supra T.C. Memo taxable income taxpayer tion trade or business transaction transfer trust U.S. dollar United Westway
Popular passages
Page 1159 - ... the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom ; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Page 1118 - Relevant evidence" means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.
Page 1159 - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...
Page 690 - Imposed by section 531 shall apply to every corporation (other than those described in subsection (b) ) formed or availed of for the purpose of avoiding the income tax with respect to Its shareholders or the shareholders of any other corporation, by permitting earnings and profits to accumulate Instead of being divided or distributed.
Page 142 - ... in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 503 - If an exchange would be within the provisions of subsection (b), (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 141 - 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.
Page 188 - In contravention of the agreement between the partners, where the circumstances do not permit a dissolution under any other provision of this section, by the express will of any partner at any time...
Page 849 - In determining his income tax. each partner shall take into account separately his distributive share of the partnership's...
Page 365 - If such trade or business does not consist of the performance of services by the taxpayer as an employee.