Reports of the United States Tax Court, Volume 81United States Tax Court, 1984 - Government publications |
From inside the book
Results 1-5 of 100
Page 19
... paid ' by petitioner in the form of cash plus a nonrecourse promissory note meets the requirements of the regulation and is deductible in the year paid or accrued . FACTS This case was submitted fully stipulated pursuant to Rule 122 ...
... paid ' by petitioner in the form of cash plus a nonrecourse promissory note meets the requirements of the regulation and is deductible in the year paid or accrued . FACTS This case was submitted fully stipulated pursuant to Rule 122 ...
Page 22
... paid or accrued in connection with mineral property as follows : ( i ) As deductions from gross income for the year the advanced royalties are paid or accrued , or ( ii ) As deductions from gross income for the year the mineral product ...
... paid or accrued in connection with mineral property as follows : ( i ) As deductions from gross income for the year the advanced royalties are paid or accrued , or ( ii ) As deductions from gross income for the year the mineral product ...
Page 23
... paid or accrued in connection with mineral property as deductions from gross income for the year the mineral product , in respect of which the advanced royalties were paid or accrued , is sold . However , in the case of advanced royalties ...
... paid or accrued in connection with mineral property as deductions from gross income for the year the mineral product , in respect of which the advanced royalties were paid or accrued , is sold . However , in the case of advanced royalties ...
Page 24
... paid or accrued is sold . In the alternative , respondent contends that if the royalty is deducti- ble when paid or accrued , then the nonrecourse note given by petitioner was contingent and speculative and therefore does not meet the ...
... paid or accrued is sold . In the alternative , respondent contends that if the royalty is deducti- ble when paid or accrued , then the nonrecourse note given by petitioner was contingent and speculative and therefore does not meet the ...
Page 38
... paid or accrued " as a result of a minimum royalty provision . Petitioner concedes that , if the amendment is valid , no deduction is allowable unless the $ 60,000 qualifies as a payment made pursuant to a " minimum royalty provision ...
... paid or accrued " as a result of a minimum royalty provision . Petitioner concedes that , if the amendment is valid , no deduction is allowable unless the $ 60,000 qualifies as a payment made pursuant to a " minimum royalty provision ...
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Common terms and phrases
9th Cir accumulated profits advanced royalties affd agreement amended amount apply assets Bell County capital carryback Cayman Islands claimed Commissioner computed Congress corporation decedent decision deduction determined distribution dividend docket earnings and profits employees estate tax exempt fact Federal income tax filed foreign personal holding foreign taxes gross income guaranteed renewable held Hospital included Income Tax Regs insurance company interest Internal Revenue Internal Revenue Code Internal Revenue Service issue KFSH Knox County lease mailed management contract noncancelable notice of deficiency obligation opinion paid parties payments percent personal holding company petition petitioner petitioner's policies preliminary term method purchase purposes pursuant qualify received regulation Rept reserve respect respondent respondent's Rule Saudi Arabia shareholders shares Simarloo statute statutory supra T.C. Memo Tax Court taxable income taxpayer tion trade or business transaction U.S. dollars unearned premiums United Universal Life Church Zappo
Popular passages
Page 744 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained 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 120 - If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance, the wife's gross income includes periodic payments (whether or not made at regular intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, in discharge of) a legal obligation which, because of the marital or family relationship, is imposed on or incurred by the husband under the decree or under a written instrument incident...
Page 94 - In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors...
Page 993 - 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...
Page 27 - ... means the whole or a part of an agency statement of general or particular applicability and future effect designed to implement, interpret, or prescribe law or policy or describing the organization, procedure, or practice requirements of an agency and includes the approval or prescription for the future of rates, wages, corporate or financial structures or reorganizations thereof, prices, facilities, appliances, services or allowances therefor or of valuations, costs, or accounting, or practices...
Page x - Romeo, and when he shall die, Take him and cut him out in little stars, And he will make the face of heaven so fine, That all the world will be in love with night, And pay no worship to the garish Sun.
Page 467 - Stock owned, directly or indirectly, by or for a corporation, partnership, estate, or trust, shall be considered as being owned proportionately by or for its shareholders, partners, or beneficiaries...
Page 28 - ... (1) a substantive rule which grants or recognizes an exemption or relieves a restriction; (2) interpretative rules and statements of policy; or (3) as otherwise provided by the agency for good cause found and published with the rule.
Page 679 - A limited partner shall not become liable as a general partner unless, in addition to the exercise of his rights and powers as a limited partner, he takes part in the control of the business.
Page 427 - (a) TREATMENT OF TAXES PAID BY FOREIGN CORPORATION. — For purposes of this subpart, a domestic corporation which owns at least 10 percent of the voting stock of a foreign corporation from which it receives dividends in any taxable year shall...