Reports of the Tax Court of the United States, Volume 80U.S. Government Printing Office, 1983 - Taxation |
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Page 4
... record of $ 20 million in sales . Petitioner then began to eye a number of smaller companies with the objective of entering the microwave industry by acquiring companies that collectively could offer a broad product line . This would ...
... record of $ 20 million in sales . Petitioner then began to eye a number of smaller companies with the objective of entering the microwave industry by acquiring companies that collectively could offer a broad product line . This would ...
Page 13
... record- ed on petitioner's General Ledger and on New GRFF's " Intercompany Account . " No transfer of assets from ... Records of Martin County , Fla . , the real property belonging to New GRFF was not transferred to petitioner until ...
... record- ed on petitioner's General Ledger and on New GRFF's " Intercompany Account . " No transfer of assets from ... Records of Martin County , Fla . , the real property belonging to New GRFF was not transferred to petitioner until ...
Page 94
... record and everything else fixed up I sent the stock certificates and all of the other books and papers pertaining to the Foster Bayou Corp. to Mr. Laney and said , in effect , " Here it is ; you can send us the agreed purchase price ...
... record and everything else fixed up I sent the stock certificates and all of the other books and papers pertaining to the Foster Bayou Corp. to Mr. Laney and said , in effect , " Here it is ; you can send us the agreed purchase price ...
Page 106
... record title holders . Both the partnership and Foster Enterprises characterized the entire amount received as severance damages and reduced their bases in their respective land holdings by said amount . In the notice of deficiency ...
... record title holders . Both the partnership and Foster Enterprises characterized the entire amount received as severance damages and reduced their bases in their respective land holdings by said amount . In the notice of deficiency ...
Page 117
... record is replete with factual inconsistencies and contradictions which the parties exploit to their own advantage in almost 1,000 pages of briefs . Nevertheless , we have done our best to reconcile the conflicting portions of the record ...
... record is replete with factual inconsistencies and contradictions which the parties exploit to their own advantage in almost 1,000 pages of briefs . Nevertheless , we have done our best to reconcile the conflicting portions of the record ...
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Common terms and phrases
9th Cir acquired adjustment affd agreement allocation Alps Corp amount application assets bank basis benefit bonds bonus Brewer's Island California capital carryback cash Champlin claimed Commissioner contract corporation Court debt decedent deduction distribution district earnings easement Estero exchange exemption expenses fact fair market value Federal income tax filed fiscal Foster Bayou Foster City Foster Enterprises Foster partnership GRFF Hoblitzelle Foundation Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service investment issue Jack Foster Kroger land lease liability Likins-Foster loan notice of deficiency operating loss paid parties partner payments percent petitioner petitioner's prior profits purposes pursuant qualified real property received record reinsurance rental Rept Republic National Bank respondent's rule San Mateo County section 482 shareholders shares specific supra T.C. Memo taxable income taxpayer tion trade or business transfer trust U.S. dollar United Westway
Popular passages
Page 142 - ... in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
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 1066 - Receipts of shipowners' mutual protection and Indemnity associations; Dividends from China Trade Act corporations; Compensation of employees of foreign governments. (c) Inventories. — Whenever In the opinion of the Commissioner the use of Inventories is necessary In order clearly to determine the Income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best...
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 845 - In determining his income tax. each partner shall take into account separately his distributive share of the partnership's...
Page 501 - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 300 - Basically, the question in each case is whether the facts alleged, under all the circumstances, show that there is a substantial controversy, between parties having adverse legal interests, of sufficient immediacy and reality to warrant the issuance of a declaratory judgment.
Page 774 - In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material incomeproducing factors...
Page 555 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close .of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Page 849 - An assignee for the benefit of creditors or any person appointed by the court shall have the right to enforce the contributions specified in clause (d) of this paragraph.