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 23
... parties were not adverse and did not deal at arm's length . Accordingly , where the parties are related , and a payment in excess of fair market value is a disguised dividend , gift , contribution to capital , or the like , the cost ...
... parties were not adverse and did not deal at arm's length . Accordingly , where the parties are related , and a payment in excess of fair market value is a disguised dividend , gift , contribution to capital , or the like , the cost ...
Page 41
... parties herein . In June 1969 , he terminated his relationship with J , D , and B. ( T had died in 1968. ) Shortly thereafter , he sued them in State court for , inter alia , allegedly failing to fully compensate him for services ...
... parties herein . In June 1969 , he terminated his relationship with J , D , and B. ( T had died in 1968. ) Shortly thereafter , he sued them in State court for , inter alia , allegedly failing to fully compensate him for services ...
Page 72
... parties were also obtained to permit the installation and maintenance of the line . In April 1962 , Estero approved a contract for the construc- tion of a 6,300 - foot sewer outfall line . It also extended an earlier contract for ...
... parties were also obtained to permit the installation and maintenance of the line . In April 1962 , Estero approved a contract for the construc- tion of a 6,300 - foot sewer outfall line . It also extended an earlier contract for ...
Page 85
... parties then shook hands . The terms of their 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 ...
... parties then shook hands . The terms of their 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 ...
Page 100
... Republic and the Howard Corp. from any claim they might have against them for usury . In this regard , the agreement provided as follows : Recitals : E. Certain of the parties included in the 100 ( 34 ) 80 UNITED STATES TAX COURT REPORTS.
... Republic and the Howard Corp. from any claim they might have against them for usury . In this regard , the agreement provided as follows : Recitals : E. Certain of the parties included in the 100 ( 34 ) 80 UNITED STATES TAX COURT REPORTS.
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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.