American Federal Tax ReportsPrentice-Hall, 2003 - Taxation |
From inside the book
Results 1-3 of 82
Page 2003-399
... reasonable cause mean " ordinary business care and pru- dence , " as set forth in Treas . Reg . ยง 301.6651-1 ( c ) ( 1 ) , and construed the term " reasonable cause " to require the " ab- sence of ... carelessness ' the taxpayer . 469 ...
... reasonable cause mean " ordinary business care and pru- dence , " as set forth in Treas . Reg . ยง 301.6651-1 ( c ) ( 1 ) , and construed the term " reasonable cause " to require the " ab- sence of ... carelessness ' the taxpayer . 469 ...
Page 2003-2546
... reasonable business needs ' for the purpose of avoiding the taxation of those amounts as dividends in the hands of the corporation's shareholders " ) . There- fore , there are two elements to the assess- ment of the tax : ( 1 ) ...
... reasonable business needs ' for the purpose of avoiding the taxation of those amounts as dividends in the hands of the corporation's shareholders " ) . There- fore , there are two elements to the assess- ment of the tax : ( 1 ) ...
Page 2003-2552
... Reasonable business needs cannot be de- termined in a vacuum or out of context of the given business or industry . In evaluat- ing petitioner's reasonable business needs , we must keep in mind the nature of peti- tioner's particular ...
... Reasonable business needs cannot be de- termined in a vacuum or out of context of the given business or industry . In evaluat- ing petitioner's reasonable business needs , we must keep in mind the nature of peti- tioner's particular ...
Contents
AFTR2d Parallel Citations Tables 11 | 2003-275 |
Case Table for Volume 91 AFTR2d 51 | 2003-283 |
Income Tax Decisions | 2003-301 |
Copyright | |
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2d Cir 5th Cir 91 AFTR action affirmed AFTR 2d agreement alleged amended amount apply Appx argues argument asserts assessment attorney audit Bank Bankr Bankruptcy Court Bktcy Ct Chevron Circuit Cite as 91 claim Code Commissioner complaint Corp counsel debtor Decision for Govt deduction defendant defendant's denied determination District Judge documents employees evidence fact filed Gambones granted hearing income tax injunction interest Internal Revenue Code Internal Revenue Service IRS's issue Judicial Watch jurisdiction jury KPMG litigation ment motion for summary notice partnership party payments penalty petition Plaintiff privilege proceeding pursuant reasonable received request Rule ruptcy Section Southern Dist statute summary judgment summons Supp tar sands Tax Court tax liability Tax Reporter tax returns taxpayer tion transaction trial trucks Trustee U.S. District Court UNITED STATES DISTRICT United States Tax violation