American Federal Tax ReportsPrentice-Hall, 2003 - Taxation |
From inside the book
Results 1-3 of 79
Page 2003-399
... reasonable cause ' mean " ordinary business care and pru- dence , " as set forth in Treas . Reg . § 301.6651-1 ( c ) ( 1 ) , and construed the term " reasonable cause " to require the " ab- sence of ... carelessness " on the part of the ...
... reasonable cause ' mean " ordinary business care and pru- dence , " as set forth in Treas . Reg . § 301.6651-1 ( c ) ( 1 ) , and construed the term " reasonable cause " to require the " ab- sence of ... carelessness " on the part of the ...
Page 2003-2547
... reasonable needs of the business . These include : ( 1 ) Loans to shareholders , or the expenditure of funds of the corporation for the personal benefit of the shareholders ; ( 2 ) Loans having no reasonable relation to the conduct of ...
... reasonable needs of the business . These include : ( 1 ) Loans to shareholders , or the expenditure of funds of the corporation for the personal benefit of the shareholders ; ( 2 ) Loans having no reasonable relation to the conduct of ...
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 ...
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5th Cir 91 AFTR action affirmed AFTR 2d agreement alleged amended amount appeal apply argues argument asserts assessment attorney Bank Bankruptcy Bankruptcy Court Circuit Cite as 91 claim collection complaint concluded considered counsel debtor decision defendant denied determination dismiss Dist District Court documents evidence fact failed federal filed Form further granted hearing income interest Internal Revenue Internal Revenue Code issue Judge Judicial jurisdiction liability lien limitations March matter ment Michigan motion notes notice opinion paid partnership party payments penalty person Plaintiff privilege proceeding pursuant reasonable received record Reference refund relief Reporter request respect response Rule Service summary judgment summons Tax Court tax returns taxpayer tion trial Trustee United UNITED STATES DISTRICT United States Tax