Reports of the United States Tax Court, Volume 95United States Tax Court, 1991 - Government publications |
From inside the book
Results 1-5 of 39
Page 40
... statute . Sec . 461 ( e ) . As to a short period , the regulations provide that amounts of dividends or interest ... limitations , as a deduction for other periods as provided in the regulations . See sec . 1.461-1 ( e ) ( 3 ) , Income ...
... statute . Sec . 461 ( e ) . As to a short period , the regulations provide that amounts of dividends or interest ... limitations , as a deduction for other periods as provided in the regulations . See sec . 1.461-1 ( e ) ( 3 ) , Income ...
Page 66
... statute of limitations , respondent accepted and ' Ella J. Brady was decedent's spouse and was formerly known as Ella J. Carberry . 2Unless otherwise indicated , all statutory references are to the Internal Revenue Code as amended and ...
... statute of limitations , respondent accepted and ' Ella J. Brady was decedent's spouse and was formerly known as Ella J. Carberry . 2Unless otherwise indicated , all statutory references are to the Internal Revenue Code as amended and ...
Page 67
United States. Tax Court. executed a Form 872 - A indefinitely extending the statute of limitations . The Form 872 - A was signed by Helen Thome , Vice President , on behalf of the decedent . Above her signature appears the following ...
United States. Tax Court. executed a Form 872 - A indefinitely extending the statute of limitations . The Form 872 - A was signed by Helen Thome , Vice President , on behalf of the decedent . Above her signature appears the following ...
Page 71
... statute of limitations , irrespective of whether it was mailed to the last known address . Frieling v . Commissioner , 81 T.C. 42 ( 1983 ) . We next address the substantive issue of whether the special allocation of partnership ...
... statute of limitations , irrespective of whether it was mailed to the last known address . Frieling v . Commissioner , 81 T.C. 42 ( 1983 ) . We next address the substantive issue of whether the special allocation of partnership ...
Page 133
... limitations period , we have jurisdiction over such years , as the statute of limitations is an affirmative defense that must be pleaded . Rule 39 ; Shopsin v . Commissioner , T.C. Memo . 1984-151 . Summary judgment would be appropriate ...
... limitations period , we have jurisdiction over such years , as the statute of limitations is an affirmative defense that must be pleaded . Rule 39 ; Shopsin v . Commissioner , T.C. Memo . 1984-151 . Summary judgment would be appropriate ...
Other editions - View all
Common terms and phrases
9th Cir additions to tax adjustments affd allocation amended Amesbury amount apply assessment assets attributable Ballard Equity cable television Calumet carryback cattle Chunchula claimed CNMI Commis compensation computed Congress corporation decedent's dismiss for lack employee estate tax excise tax facts Federal feedlot FPAA franchise Garnac grain Guam included Income Tax Regs interest Internal Revenue Code Internal Revenue Service investment issue lease legislative history limited loan Matherne maximum marital deduction meaning of section motion to dismiss notice of deficiency opinion paid parties partnership items payments percent period person petitioner petitioner's prior provides purposes pursuant recapture agreement redetermination regulations Rept respect Respondent determined rule shareholders sioner spouse Stabiflex statute statute of limitations statutory stipulated subchapter subsidiary supra T.C. Memo Tax Court tax liability tax matters partner taxable income taxpayer tion transaction Trust U.S. Steel United valuation Wallace WROG
Popular passages
Page 634 - Except when notice or hearing is required by statute, this subsection does not apply: (A) to interpretative rules, general statements of policy, or rules of agency organization, procedure, or practice...
Page 272 - Except as provided in section 276 — (a) GENERAL RULE. — The amount of income taxes imposed by this chapter shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period.
Page 46 - Congress — but the power to adopt regulations to carry into effect the will of Congress as expressed by the statute. A regulation which does not do this, but operates to create a rule out of harmony with the statute, is a mere nullity.
Page 34 - ... upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income.
Page 253 - Any such liability may be either as to the amount of tax shown on the return or as to any deficiency In tax.
Page 160 - Structure" means that which is built or constructed, an edifice or building of any kind, or any piece of work artificially built up or composed of parts joined together in some definite manner.
Page 426 - TRUST OR ANNUITY PLAN AND COMPENSATION UNDER A DEFERREDPAYMENT PLAN.
Page 598 - Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America...
Page 344 - Whoever makes or presents to any person or officer in the civil; military, or naval service of the United States, or to any department or agency thereof, any claim upon or against the United States, or any department or agency thereof, knowing such claim to be false,. fictitious, or fraudulent, shall be fined not more than $10,000 or imprisoned not more than five years, or both.
Page 121 - Division 5 of this code shall be liberally construed by the courts with the purpose of extending their benefits for the protection of persons injured in the course of their employment.