Reports of the Tax Court of the United States, Volume 101U.S. Government Printing Office, 1993 - Taxation |
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9th Cir addition to tax adjustment administration expenses affd allocated amount apply assessment assets Bugaboo claims Clayton Act Commis Commissioner corporation Court of Appeals Cramer cushion gas decedent decedent's death discount Electric and Tokyo equitable recoupment Estate Tax Regs fair market value filed gift tax gross estate Hayes included Income Tax Regs interest Internal Revenue Code Internal Revenue Service inventory issue Jung Corp line pack gas lump sum distribution marital deduction ment natural gas notice of deficiency nunc pro tunc parties partnership payments percent period of limitations peti petitioner Petitioner argues petitioner's Phillips power of appointment provides purposes pursuant qualified regulations Rept respect respondent's Robinson rule settlement agreement share shareholders sioner SoCalGas statute sum distribution supra T.C. Memo tar sands Tax Court tax return taxable income taxpayer tion Tokyo Electric Tokyo Gas transfer trust United valuation
Popular passages
Page 304 - ... 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 542 - The right to discharge is also an important factor indicating that the person possessing that right is an employer. Other factors characteristic of an employer, but not necessarily present in every case, are the furnishing of tools and the furnishing of a place to work, to the individual who performs the services.
Page 304 - To the extent of any interest therein of which the decedent has 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 304 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...
Page 466 - Whenever in the opinion of the Commissioner the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income.
Page 363 - If a return is made under paragraph (1) of subsection (a), the taxable income for the short period shall be placed on an' annual basis by multiplying such income by 12 and dividing the result by the number of months in the short period. The tax shall be the same part of the tax computed on the annual basis as the number of months in the short period is of 12 months.
Page 116 - Gains, profits and income from (1) transportation or other services rendered partly within and partly without the United States, or (2) from the sale of personal property produced (in whole or in part) by the taxpayer within and sold without the United States, or produced (in whole or in part) by the taxpayer without and sold within the United States, shall be treated as derived partly from sources within and partly from' sources without the United States.
Page 297 - If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 per centum of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 5 years after the return was filed.
Page 467 - Where the taxpayer maintains book inventories in accordance with a sound accounting system in which the respective inventory accounts are charged with the actual cost of the goods purchased or produced and credited with the value of goods used, transferred, or sold, calculated upon the basis of the actual cost of the goods acquired during the taxable year (including the inventory at the beginning of the year), the net value as shown by such inventory accounts will be deemed to be the cost of the...
Page 56 - ... takes effect only on the expiration of a stated period after the exercise of the power, whether or not on or before the date of the decedent's death notice has been given or the power has been exercised.