Reports of the United States Tax Court, Volume 96United States Tax Court, 1991 - Government publications |
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Common terms and phrases
9th Cir accounting adjustment affd Allstate amended AMERCO amount applicable Arcelo Arthur Andersen assets captive insurance certificates claims Commissioner computed Corp corporation costs CSD's decedent decedent's deduction deposits determined DiLeo employees estate tax expenses Federal income tax filed foreign tax credit FSAA gross Gulf Oil Corp included Income Tax Regs income tax returns incurred insurance company interest Internal Revenue Internal Revenue Code investment issue liability loans loss Lucas Lynk manufacturing method mortgage Mycek notice of deficiency opinion paid parties partnership items payment percent petition petitioner petitioner's policies premiums profits purchase pursuant qualified regulations reserve respect respondent respondent's risk royalty Rule SABENA Seven-Up Shadow Stock shareholders shares Singapore sioner spare statutory subchapter subsidiary SunPac license agreement supra taxable income taxpayer Teijin term life insurance tion transaction transfer trust U-Haul United unrelated windfall profit tax
Popular passages
Page 679 - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
Page 901 - HR 32, before the Subcommittee on Civil and Constitutional Rights of the House Committee on the Judiciary, 94th Cong., 2d Sess.
Page 496 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include — "(A) 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 623 - ... the basis of the property in the hands of the distributee shall be the adjusted basis of the stock with respect to which the distribution was made.
Page 894 - At the request of a party the court shall order witnesses excluded so that they cannot hear the testimony of other witnesses, and it may make the order of its own motion. This rule does not authorize exclusion of (1) a party who is a natural person, or (2) an officer or employee of a party which is not a natural person designated as its representative by its attorney, or (3) a person whose presence is shown by a party to be essential to the presentation of the party's cause, or (4) a person authorized...
Page 462 - The proceedings of the Board and its divisions shall be conducted in accordance with such rules of practice, and procedure (other than rules of evidence) as the Board may prescribe and in accordance with the rules of evidence applicable in courts of equity of the District of Columbia.
Page 711 - Notwithstanding the provisions of section 7421(a), the making of such assessment or the beginning of such proceeding or levy during the time such prohibition is In force may be enjoined by a proceeding In the proper court.
Page 679 - The value of the gross estate shall include the value of all property — (1) Transfers after June 22, 1936. — To the extent of any interest therein of which the decedent at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money's worth...
Page 880 - False return. — In the case of a false or fraudulent return with the intent to evade tax, the tax may be assessed, or a proceeding in court for collection of such tax may be begun without assessment, at any time.
Page 418 - States, upon or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of such dividends bears to the amount of such accumulated profits...