Reports of the Tax Court of the United States, Volume 104U.S. Government Printing Office, 1995 - Taxation |
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9th Cir addition to tax ADPR Afex option affd agreement Allen Leavell amount ANCSA apply apportionment assets attorney-client privilege Brinco Brown Cayman carryback cash claim Club combined report Commissioner Congress Conoco containers contract costs Court of Appeals decedent decedent's deduction determined distribution DuPont Ekofisk employees fair market value Federal income tax filed Flexi-Van foreign source Fortress generation-skipping transfer taxes gross income Income Tax Regs income tax return interest Internal Revenue Internal Revenue Code issue lease marital deduction ment merger method norm price Norris Norway notice of deficiency notices of allocation paid parties partnership payment percent peti petitioner petitioner's petroleum Player profit purchase pursuant regulation reinsurance respect respondent respondent's rule shareholders source gross income statute supra T.C. Memo Tax Court taxable income taxpayer tender offer Tenderor Tenneco Teorco tion tioner U.S. dollar United VEBA
Popular passages
Page 633 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.
Page 652 - ... (i) if an interest in such property passes or has passed (for less than an adequate and full consideration in money or money's worth) from the decedent to any person other than such surviving spouse (or the estate of such spouse...
Page 511 - Code provides that the value of the gross estate shall include the value of all property to the extent of any interest therein of which the decedent...
Page 233 - But where the second action between the same parties is upon a different claim or demand, the judgment in the prior action operates as an estoppel only as to those matters in issue or points controverted, upon the determination of which the finding or verdict was rendered.
Page 546 - State through a broker, general commission agent or any other agent of an independent status, where such persons are acting in the ordinary course of their business.
Page 90 - Immediately before the acquisition) ; (C) the acquisition by one corporation. In exchange solely for all or a part of its voting stock (or In exchange solely for all or a part of the voting stock of a corporation which Is In control of the acquiring corporation), of substantially all of the properties of another corporation...
Page 178 - The doctrine of corporate entity fills a useful purpose in business life. Whether the purpose be to gain an advantage under the law of the state of incorporation or to avoid or to comply with the demands of creditors or to serve the creator's personal or undisclosed convenience, so long as that purpose is the equivalent of business activity or is followed by the carrying on of business by the corporation, the corporation remains a separate taxable entity.
Page 725 - States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be allocated to some item or class of gross income. The remainder, if any, shall be included in full as net income from sources within the United States.
Page 374 - ... (b) Exceptions. If no method of accounting has been regularly used by the taxpayer, or if the method used does not clearly reflect income, the computation of taxable income shall be made under such method as, in the opinion of the Secretary or his delegate, does clearly reflect income.
Page 724 - Congress has not directly addressed the precise question at issue, the court does not simply impose its own construction on the statute, as would be necessary in the absence of an administrative interpretation. Rather, if the statute is silent or ambiguous with respect to the specific issue, the question for the court is whether the agency's answer is based on a permissible construction of the statute.