Reports of the Tax Court of the United States, Volume 94U.S. Government Printing Office, 1990 - Taxation |
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9th Cir addition to tax Admiral Beach affd amended amount apply argues assets Bajan Bank Barbados basis carryback cash surrender value claimed collateral estoppel Commissioner common stock computed Congress contract corporation Court of Appeals decedent decedent's deduction dividends docket donor list entitled estate tax expenses facts Federal income tax filed FPAA geothermal Goldman Sachs golf course GSDII home office included Income Tax Regs income tax return interest Internal Revenue Internal Revenue Code Iran issue lease liability loss mailing marital deduction master recordings Medford motion notice of deficiency operation opinion parties partner partnership payments percent petition petitioner petitioner's place of business preferred shareholders preferred stock principal place purchase pursuant received references rent rental reported repos respondent's royalties Rule shares special trial judges statute statutory stipulated supra T-Bills T.C. Memo Tax Court taxable income taxpayer tion trade or business transactions trust United
Popular passages
Page 209 - 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 401 - ... may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses. if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 336 - For the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including amounts paid for accident or health insurance) , or (B) For transportation primarily for and essential to medical care referred to in subparagraph (A).
Page 577 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind...
Page 655 - All the rest, residue and remainder of all 196 US Statement of the Case. the property and estate, real, personal and mixed, of every description, and wheresoever situated, of which I may die seized or possessed...
Page 248 - There shall be allowed as a deduction any loss sustained during the taxable year and not compensated for by insurance or otherwise.
Page 457 - 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 535 - Payments for the use or occupancy of rooms or other space where services are also rendered to the occupant, such as for the use or occupancy of rooms or other quarters in hotels, boarding houses, or apartment houses furnishing hotel services, or in tourist camps or tourist homes, or payments for the use or occupancy of space in parkin? lots, warehouses, or storage garages, do not constitute rentals from real estate; consequently, such payments are included in determining net earnings from self-employment.
Page 320 - ... even if such taxpayer is deceased, or is under a legal disability, or. in the case of a corporation, has terminated its existence.
Page 15 - 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.