Reports of the United States Tax Court, Volume 80United States Tax Court, 1983 - Government publications |
From inside the book
Results 1-5 of 100
Page 38
... involved in the development of Foster City . Sec . 1.482-1 ( b ) ( 3 ) , Income Tax Regs . Respondent's failure to do so does not demonstrate any abuse of discretion on his part . ( Pp . 191-195 . ) Issue 2 : APPLICABILITY OF THE ...
... involved in the development of Foster City . Sec . 1.482-1 ( b ) ( 3 ) , Income Tax Regs . Respondent's failure to do so does not demonstrate any abuse of discretion on his part . ( Pp . 191-195 . ) Issue 2 : APPLICABILITY OF THE ...
Page 41
... involved services which C rendered in his capacity as their tax counselor during the development of Foster City . The tax consequences of those services were at issue in the State court action , just as they are at issue in the present ...
... involved services which C rendered in his capacity as their tax counselor during the development of Foster City . The tax consequences of those services were at issue in the State court action , just as they are at issue in the present ...
Page 44
... the Foster partnership ' Petitioners do not allege the amount of overpayment claimed for each specific set of petitioners . with all of the Foster - controlled corporations purportedly involved 44 ( 34 ) 80 UNITED STATES TAX COURT REPORTS.
... the Foster partnership ' Petitioners do not allege the amount of overpayment claimed for each specific set of petitioners . with all of the Foster - controlled corporations purportedly involved 44 ( 34 ) 80 UNITED STATES TAX COURT REPORTS.
Page 47
... involvement in Issue 8 , the female petitioners are parties to this action solely by virtue of having filed joint returns with their respective spouses . Accordingly , " the Fosters " will only refer to the principals involved in this ...
... involvement in Issue 8 , the female petitioners are parties to this action solely by virtue of having filed joint returns with their respective spouses . Accordingly , " the Fosters " will only refer to the principals involved in this ...
Page 50
... involved in the family business . In 1960 , he moved to Honolulu in order to manage the Fosters ' operations and thereby allow Jack , Jr. , to assume his responsibilities at Foster City . While in Hawaii , he supervised the construction ...
... involved in the family business . In 1960 , he moved to Honolulu in order to manage the Fosters ' operations and thereby allow Jack , Jr. , to assume his responsibilities at Foster City . While in Hawaii , he supervised the construction ...
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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.