Reports of the Tax Court of the United States, Volume 91U.S. Government Printing Office, 1989 - Taxation |
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Common terms and phrases
9th Cir AARK Acquired Banks activity addition to tax affd affg agreement amended amount apply assets capital Carlton cash claimed collateral estoppel Commissioner contract core deposits corporation costs debt decedent's December 31 defendant Meier deposit base distribution entitled equipment estate tax evidence expenses export facts fair market value Federal income tax fees filed funds futures contracts grand jury Hatsis held Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service investment investors issue lease liability litigation loan loss marital deduction notice of deficiency opinion ordinary income paid parties partners payments percent petition petitioner petitioner's profit promissory note purchase pursuant qualified received record regulations respect respondent's share shareholders statute stipulated substantial supra T.C. Memo Tax Court taxable taxpayer tion trade or business transactions transfers trial trust Tudor United Universal Life Church Urban
Popular passages
Page 310 - ... due process requires only that in order to subject a defendant to a judgment in personam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend "traditional notions of fair play and substantial justice.
Page 342 - ... to the best of his knowledge, information, and belief formed after reasonable inquiry it is well grounded in fact and is warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law, and that it is not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation.
Page 1080 - The amount of all such items shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under methods of accounting permitted under subdivision (b) of section 212, any such amounts are to be properly accounted for as of a different period...
Page 596 - The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same provisions and limitations...
Page 1014 - Except as otherwise provided in section 6861 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 78 - This decision appears to fall in that small class which finally determine claims of right separable from, and collateral to, rights asserted in the action, too important to be denied review and too independent of the cause itself to require that appellate consideration be deferred until the whole case is adjudicated.
Page 334 - If his surviving spouse is entitled for life to all the Income from the entire interest, or all the income from a specific portion...
Page 61 - B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders, par. 10.05 (5th ed. 1987). Petitioners...
Page 105 - ... no substantial part of the activities of which is carrying on propaganda, or otherwise attempting to influence legislation, and which does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of any candidate for public office.
Page 105 - The amount of all bequests, legacies, devises, or transfers, to or for the use of the United States, any State, Territory, any political subdivision thereof, or the District of Columbia, for exclusively public purposes, or to or for the use of any corporation organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes...