Reports of the United States Tax Court, Volume 80United States Tax Court, 1983 - Government publications |
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Results 1-5 of 100
Page 6
... really had an opportunity to qualify or modify its product in accordance with specification sheets because of its acquisition by petitioner . closed on August 29 , 1968 , pursuant to letter 6 ( 1 ) 80 UNITED STATES TAX COURT REPORTS.
... really had an opportunity to qualify or modify its product in accordance with specification sheets because of its acquisition by petitioner . closed on August 29 , 1968 , pursuant to letter 6 ( 1 ) 80 UNITED STATES TAX COURT REPORTS.
Page 10
... qualified : Charles Whorl Joseph Friedman Richard Trivison ( S ) Benjamin Friedman BENJAMIN FRIEDMAN , President Solitron Devices , Inc. " New GRFF did not entirely terminate its production of custom - made connectors , because it felt ...
... qualified : Charles Whorl Joseph Friedman Richard Trivison ( S ) Benjamin Friedman BENJAMIN FRIEDMAN , President Solitron Devices , Inc. " New GRFF did not entirely terminate its production of custom - made connectors , because it felt ...
Page 11
... qualified . Charles Whorl Joseph Friedman Richard Trivison ( S ) Beniamin Friedman BENJAMIN FRIEDMAN , President Solitron Devices , Inc. Another document entitled " Minute of Action of the Share- holders of General RF Fittings , Inc ...
... qualified . Charles Whorl Joseph Friedman Richard Trivison ( S ) Beniamin Friedman BENJAMIN FRIEDMAN , President Solitron Devices , Inc. Another document entitled " Minute of Action of the Share- holders of General RF Fittings , Inc ...
Page 12
... qualified . Charles Whorl Joseph Friedman Richard Trivison BENJAMIN FRIEDMAN , President Solitron Devices , Inc. Also submitted into evidence was a document entitled " Assignment of Assets From General RF Fittings , Inc. To Solitron ...
... qualified . Charles Whorl Joseph Friedman Richard Trivison BENJAMIN FRIEDMAN , President Solitron Devices , Inc. Also submitted into evidence was a document entitled " Assignment of Assets From General RF Fittings , Inc. To Solitron ...
Page 34
... qualify as investment income for sec . 163 ( d ) purposes . Congressional action , however , taken in 1982 does not change the result of this case . Since a special provision was no longer needed to attribute the character of investment ...
... qualify as investment income for sec . 163 ( d ) purposes . Congressional action , however , taken in 1982 does not change the result of this case . Since a special provision was no longer needed to attribute the character of investment ...
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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.