Reports of the Tax Court of the United States, Volume 81U.S. Government Printing Office, 1984 - Taxation |
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Page xxiii
... pursuant to the procedures prescribed therein . Such assignments have assisted the Court materially in its efforts to provide for the efficient and expeditious disposition of an ever increasing number of cases being filed . Subsequent ...
... pursuant to the procedures prescribed therein . Such assignments have assisted the Court materially in its efforts to provide for the efficient and expeditious disposition of an ever increasing number of cases being filed . Subsequent ...
Page xxiv
... pursuant to the authority of such rule to provide otherwise , such procedures shall not be applicable in cases assigned to Special Trial Judges in accordance with this order . C. Opinions and Decisions 1. Cases where the amount of ...
... pursuant to the authority of such rule to provide otherwise , such procedures shall not be applicable in cases assigned to Special Trial Judges in accordance with this order . C. Opinions and Decisions 1. Cases where the amount of ...
Page 1
... se . Anthony A. Falzone , for the respondent . DRENNEN , Judge : This case was assigned to and heard by Special Trial Judge John J. Pajak pursuant to the provisions of 1 section 7456 ( c ) of the Internal Revenue Code1 REPORTS ...
... se . Anthony A. Falzone , for the respondent . DRENNEN , Judge : This case was assigned to and heard by Special Trial Judge John J. Pajak pursuant to the provisions of 1 section 7456 ( c ) of the Internal Revenue Code1 REPORTS ...
Page 2
... Pursuant to the order of assignment , on the authority of the " otherwise provided " language of Rule 182 , the post - trial procedures set forth in that Rule are not applicable in this case . ' Respondent also determined that ...
... Pursuant to the order of assignment , on the authority of the " otherwise provided " language of Rule 182 , the post - trial procedures set forth in that Rule are not applicable in this case . ' Respondent also determined that ...
Page 9
... Pursuant to an elaborate surveillance program conducted at Caesar's Palace on 48 days during the period Feb. 9 , 1976 , through Jan. 26 , 1977 , respondent determined petition- ers underreported their toke income during the relevant ...
... Pursuant to an elaborate surveillance program conducted at Caesar's Palace on 48 days during the period Feb. 9 , 1976 , through Jan. 26 , 1977 , respondent determined petition- ers underreported their toke income during the relevant ...
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Common terms and phrases
9th Cir accumulated profits advanced royalties affd agreement amended amount apply assets Bell County capital carryback Cayman Islands claimed Commissioner computed Congress corporation decedent deduction determined distribution dividend docket earnings and profits employees estate tax expenses fact Federal income tax filed foreign personal holding foreign taxes gross income guaranteed renewable held Hospital included Income Tax Regs insurance company interest Internal Revenue Internal Revenue Code Internal Revenue Service issue KFSH Knox County lease loan mailed management contract noncancelable notice of deficiency obligation opinion paid parties payments percent personal holding company petition petitioner petitioner's policies preliminary term method purchase purposes pursuant qualify received regulation Rept reserve respect respondent respondent's Rule Saudi Arabia shareholders shares Simarloo statute statutory supra T.C. Memo Tax Court taxable income taxpayer tion trade or business transaction U.S. dollars unearned premiums United Universal Life Church Zappo
Popular passages
Page 742 - ... 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 468 - An individual shall be considered as owning the stock owned, directly or indirectly, by or for his family or by or for his partner.
Page 94 - In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors...
Page 27 - ... means the whole or a part of an agency statement of general or particular applicability and future effect designed to implement, interpret, or prescribe law or policy or describing the organization, procedure, or practice requirements of an agency and includes the approval or prescription for the future of rates, wages, corporate or financial structures or reorganizations thereof, prices, facilities, appliances, services or allowances therefor or of valuations, costs, or accounting, or practices...
Page x - Romeo, and when he shall die, Take him and cut him out in little stars, And he will make the face of heaven so fine, That all the world will be in love with night, And pay no worship to the garish Sun.
Page 951 - ... no assessment of a deficiency in respect of any tax imposed by subtitle A or B and no levy or proceeding in court for its collection shall be made, begun, or prosecuted until such notice has been mailed to the taxpayer, nor until the expiration of such...
Page 334 - For purposes of this subtitle, the term "life insurance company" means an insurance company which is engaged in the business of issuing life insurance and annuity contracts (either separately or combined with health and accident insurance), or noncancellable contracts of health and accident insurance...
Page 28 - ... (1) a substantive rule which grants or recognizes an exemption or relieves a restriction; (2) interpretative rules and statements of policy; or (3) as otherwise provided by the agency for good cause found and published with the rule.
Page 427 - (a) TREATMENT OF TAXES PAID BY FOREIGN CORPORATION. — For purposes of this subpart, a domestic corporation which owns at least 10 percent of the voting stock of a foreign corporation from which it receives dividends in any taxable year shall...
Page 479 - Congress intended that profits and losses arising from the everyday operation of a business be considered as ordinary income or loss rather than capital gain or loss.