Reports of the United States Tax Court, Τόμος 87United States Tax Court, 1987 |
Άλλες εκδόσεις - Προβολή όλων
Συχνά εμφανιζόμενοι όροι και φράσεις
9th Cir addition to tax adjusted basis affd agreement amended amount apply argues assets attributable Barbara Cox Anthony bargain sale beano capital gain cash charitable contribution claimed Comdisco Commissioner common stock contract corporation costs Court decedent December December 31 deduction depreciation determined disk drive dividend Docket easement election equipment expenses facts fair market value Federal income tax fees filed gift tax Grabowski Gulf Gulftankers held Housatonic River Hurchalla Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue lease liability LIFO Lorelei Marywood ment notice of deficiency opinion ordinary income paid parties partner partnership payable payments percent petitioner petitioner's platform private placement memorandum purposes pursuant received redemption regulations respect respondent respondent's royalties Rule shareholders shares Stanley Works property statutory subsidiary supra T.C. Memo taxable taxpayer tion transaction transfer trust United valuation
Δημοφιλή αποσπάσματα
Σελίδα 216 - When a motion for summary judgment is made and supported as provided in this rule, an adverse party may not rest upon the mere allegations or denials of his pleading, but his response, by affidavits or as otherwise provided in this rule, must set forth specific facts showing that there is a genuine issue for trial. If he does not so respond, summary judgment, if appropriate, shall be entered against him.
Σελίδα 245 - Every person who, under color of any statute, ordinance, regulation, custom, or usage of any State or Territory, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.
Σελίδα 739 - A casual sale or other casual disposition of personal property (other than property of a kind which would properly be included In the inventory of the taxpayer if on hand at the close of the taxable year) for a price exceeding $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed In subsection (a).
Σελίδα 895 - 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 sell and both having reasonable knowledge of relevant facts.
Σελίδα 231 - ... 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 (1) the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money's...
Σελίδα 538 - Bona fide resident of foreign country. In the case of an Individual citizen of the United States who establishes to the satisfaction of the Secretary or his delegate that he has been a bona fide resident of a foreign country or countries...
Σελίδα 340 - Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate ; 3.
Σελίδα 507 - Stock possessing at least 80 percent of the voting power of all classes of stock and at least 80 percent of each class of the nonvoting stock...
Σελίδα 538 - ... amounts received from sources without the United States (except amounts paid by the United States or any agency thereof) if such amounts constitute earned income (as defined in subsection (b)) attributable to such period...
Σελίδα 101 - other relevant factors" referred to in subparagraphs (1) and (2) of this paragraph are: The goodwill of the business; the economic outlook in the particular industry; the company's position in the industry and its management; the degree of control of the business represented by the block of stock to be valued; and the values of securities of corporations engaged in the same or similar lines of business which are listed on a stock exchange.