Reports of the Tax Court of the United States, Volume 70U.S. Government Printing Office, 1978 - Taxation |
From inside the book
Results 1-5 of 99
Page 53
... basis . In January of 1971 the Town of Niagara ( hereinafter Town ) enacted a Sewer Service Charge Ordinance ( hereinafter Sewer Ordinance ) which prescribed sewer service charges for users within the Town of Niagara Sewer District ...
... basis . In January of 1971 the Town of Niagara ( hereinafter Town ) enacted a Sewer Service Charge Ordinance ( hereinafter Sewer Ordinance ) which prescribed sewer service charges for users within the Town of Niagara Sewer District ...
Page 55
... basis taxpayers . 3 In seeking to justify their deduction , petitioners here rely exclusively upon section 461 ( f ) which provides , in pertinent part , that : ( f ) CONTESTED LIABILITIES . - If- ( 1 ) the taxpayer contests an asserted ...
... basis taxpayers . 3 In seeking to justify their deduction , petitioners here rely exclusively upon section 461 ( f ) which provides , in pertinent part , that : ( f ) CONTESTED LIABILITIES . - If- ( 1 ) the taxpayer contests an asserted ...
Page 57
... basis taxpayers , like petitioners , may deduct expenses only " for the taxable year in which paid . " Sec . 1.461- 1 ( a ) ( 1 ) , Income Tax Regs . Checks do not represent final payment relieving a debtor of liability , but rather ...
... basis taxpayers , like petitioners , may deduct expenses only " for the taxable year in which paid . " Sec . 1.461- 1 ( a ) ( 1 ) , Income Tax Regs . Checks do not represent final payment relieving a debtor of liability , but rather ...
Page 58
... basis method of accounting . Petitioners , while at times appearing to accept this analysis , seek to factually ... basis as well as accrual basis taxpayers . Certainly petitioner , a cash basis taxpayer , cannot claim a deduction in ...
... basis method of accounting . Petitioners , while at times appearing to accept this analysis , seek to factually ... basis as well as accrual basis taxpayers . Certainly petitioner , a cash basis taxpayer , cannot claim a deduction in ...
Page 118
... basis petitioners advance for this accumulation is proposed expansion and modernization of Atlas ' physical facilities . See sec . 1.537-2 ( b ) ( 1 ) , Income Tax Regs . The record shows that Atlas had a history of physical expansion ...
... basis petitioners advance for this accumulation is proposed expansion and modernization of Atlas ' physical facilities . See sec . 1.537-2 ( b ) ( 1 ) , Income Tax Regs . The record shows that Atlas had a history of physical expansion ...
Other editions - View all
Common terms and phrases
9th Cir acquired affd agreement allocated amended amount annuity apply Arthur Smith assets Atlas Bank basis benefit capital carryback cash claimed COMMISSIONER OF INTERNAL community property contract Corp corporation Court decedent decedent's December December 31 decision distribution dividends divorce employee entitled estate tax exempt expenses facts fair market value Federal income tax fees filed franchise funds gross income Hayden Stone held Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service investment issue KBSI liability loan loss Malag marital deduction notice of deficiency operating organization paid parties partnership payable payments percent period petition petitioner petitioner's players prior proceeds purchase purposes pursuant qualified received regulations reorganization Rept respect Respondent determined RESPONDENT Docket respondent's Rule shareholders shares statutory stipulated supra taxable taxpayer transaction transfer trust trust instrument United Yawata
Popular passages
Page 584 - The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.
Page 377 - ... organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or...
Page 6 - For the production or collection of income; (2) For the management, conservation, or maintenance of property held for the production of income; or (3) ln connection with the determination, collection, or refund of any tax.
Page 202 - Compulsory Counterclaims. A pleading shall state as a counterclaim any claim which at the time of serving the pleading the pleader has against any opposing party, if it arises out of the transaction or occurrence that is the subject matter of the opposing party's claim...
Page 80 - While the question of dependency may involve principles of law, the fact remains that dependency is a question of fact to be determined from all the circumstances of the case and the burden of proving it rests upon him who claims it.
Page 143 - An individual who is legally separated from his spouse under a decree of divorce or of separate maintenance shall not be considered as married...
Page 175 - Is to be paid or may be paid over a period ending more than 10 years from the date of such decree...
Page 345 - An order striking out pleadings or parts thereof, or staying further proceedings until the order is obeyed, or dismissing the action or proceeding or any part thereof, or rendering a judgment by default against the disobedient party...
Page 617 - If, however, an intangible asset acquired through capital outlay is known from experience to be of value in the business or in the production of income for only a limited period, the length of which can be estimated from experience with reasonable certainty, such intangible asset may be the subject of a depreciation allowance, provided the facts are fully shown in the return or prior thereto to the satisfaction of the Commissioner.
Page 714 - ... Generally, services are considered rendered to the occupant if they are primarily for his convenience and are other than those usually or customarily rendered in connection with the rental of rooms or other space for occupancy only.