Reports of the Tax Court of the United States, Volume 67U.S. Government Printing Office, 1977 - Taxation |
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Page 20
... effect on the burden of proof than if it had been raised in his original return . Petitioner first formally raised his present contention in an amended partnership return filed after the notice of deficiency was issued and renewed it in ...
... effect on the burden of proof than if it had been raised in his original return . Petitioner first formally raised his present contention in an amended partnership return filed after the notice of deficiency was issued and renewed it in ...
Page 27
... effect of an amendment on a previously qualified plan or the effect of termination on the 1 Statutory references are to the Internal Revenue Code of 1954 , unless otherwise indicated . continued qualification of a previously qualified ...
... effect of an amendment on a previously qualified plan or the effect of termination on the 1 Statutory references are to the Internal Revenue Code of 1954 , unless otherwise indicated . continued qualification of a previously qualified ...
Page 37
... . All section references are to the Internal Revenue Code of 1954 , as in effect during the tax year in issue , unless otherwise noted . Mid - Continent Supply Co. ( hereinafter referred to as MID - CONTINENT SUPPLY CO . 37.
... . All section references are to the Internal Revenue Code of 1954 , as in effect during the tax year in issue , unless otherwise noted . Mid - Continent Supply Co. ( hereinafter referred to as MID - CONTINENT SUPPLY CO . 37.
Page 41
... effect treats the taxpayer's income as being divisible into two parts , domestic and foreign . Thus , under this limitation a foreign tax credit is allowed for any foreign income taxes so long as these taxes do not represent more than ...
... effect treats the taxpayer's income as being divisible into two parts , domestic and foreign . Thus , under this limitation a foreign tax credit is allowed for any foreign income taxes so long as these taxes do not represent more than ...
Page 42
... effect , then the amount of taxes paid or accrued to foreign countries and possessions of the United States by such Western Hemisphere trade corporations which may be taken into account for purposes of section 901 shall be reduced by ...
... effect , then the amount of taxes paid or accrued to foreign countries and possessions of the United States by such Western Hemisphere trade corporations which may be taken into account for purposes of section 901 shall be reduced by ...
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Common terms and phrases
5th Cir affd agreement allocated amended amount applicable Assemblies of God assets basis Camous claimed compensation computation contract Corp cost decedent decedent's December December 16 deduction depreciation disallowed distribution dividend earnings and profits employees entitled estate tax facts Federal income tax filed Frick Building funds gift tax gross income Harder Tree held hereinafter included Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service issue Las Vegas lease liability Nevada test site notice of deficiency October 31 opinion option paid parties partnership payments percent period petition petitioner petitioner's prior purchase purposes pursuant received redemption REECO resided respect Respondent determined RESPONDENT Docket respondent's Rule September 30 shareholders shares spouse statute statutory stipulated subsidiary supra Tax Court taxable income taxable year ended taxable years 1970 taxpayer tion transaction transfer trust United Webb WHTCs
Popular passages
Page 978 - ... owned or controlled directly or indirectly by the same interests, the Secretary or his delegate 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 490 - IB for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary...
Page 672 - Court pursuant to statutory authority, the privilege of a witness, person, government, State, or political subdivision thereof shall be governed by the principles of the common law as they may be interpreted by the courts of the United States in the light of reason and experience.
Page 187 - Except as provided in section 276 — (a) GENERAL RULE. — The amount of income taxes imposed by this title shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period.
Page 217 - A court of the United States shall have power to punish by fine or imprisonment, at its discretion, such contempt of its authority, and none other, as — "(1) Misbehavior of any person in its presence or so near thereto as to obstruct the administration of justice; "(2) Misbehavior of any of its officers in their official transactions; "(3) Disobedience or resistance to its lawful writ, process, order, rule, decree, or command.
Page 168 - A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
Page 386 - Deductions otherwise allowed by law not attributable to the operation of a trade or business regularly carried on by the taxpayer...
Page xxv - Trade or business expenses — (a) In general. There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business...
Page 132 - ... (4) if the contributions or benefits provided under the plan do not discriminate in favor of employees who are officers, shareholders, persons whose principal duties consist in supervising the work of other employees, or highly compensated employees.
Page 100 - There shall be allowed as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear (including a reasonable allowance for obsolescence) — (!) of property used in the trade or business, or (2) of property held for the production of income.