Reports of the Tax Court of the United States, Volume 68U.S. Government Printing Office, 1977 |
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Halaman 41
... losses as follows : Year 1968 Amount $ 11,418.73 1969 88,947.98 1970 ( Jan. 1 - Mar . 31 ) ... 24,888.72 Total ...... 125,255.43 The correct operating loss for the short taxable year January 1 , 1970 , through March 31 , 1970 , is ...
... losses as follows : Year 1968 Amount $ 11,418.73 1969 88,947.98 1970 ( Jan. 1 - Mar . 31 ) ... 24,888.72 Total ...... 125,255.43 The correct operating loss for the short taxable year January 1 , 1970 , through March 31 , 1970 , is ...
Halaman 42
... losses sustained by a member of the group in separate return years may be taken into account ) contained in section 1.1502-21 ( c ) , Income Tax Regs . The latter section limits the net operating loss carryovers from separate return ...
... losses sustained by a member of the group in separate return years may be taken into account ) contained in section 1.1502-21 ( c ) , Income Tax Regs . The latter section limits the net operating loss carryovers from separate return ...
Halaman 43
... losses is concerned . The essence of petitioner's rather convoluted argument is that the term " common parent ” can ... loss carryovers ( 2 ) Exceptions . The term " separate return limitation year " shall not include— ( i ) A separate ...
... losses is concerned . The essence of petitioner's rather convoluted argument is that the term " common parent ” can ... loss carryovers ( 2 ) Exceptions . The term " separate return limitation year " shall not include— ( i ) A separate ...
Halaman 44
... losses will get the majority of the benefits from the carryover deduction . " Petitioner's argument is without merit . Initially , we think it highly significant that prior to 1928 brother - sister corpora- tions were permitted to file ...
... losses will get the majority of the benefits from the carryover deduction . " Petitioner's argument is without merit . Initially , we think it highly significant that prior to 1928 brother - sister corpora- tions were permitted to file ...
Halaman 45
... loss carryovers from separate return years is that the other provisions of the Code dealing with carryovers of losses ( to wit , secs . 269 , 381 , and 382 ) and cases decided thereunder would not bar carryovers in comparable situations ...
... loss carryovers from separate return years is that the other provisions of the Code dealing with carryovers of losses ( to wit , secs . 269 , 381 , and 382 ) and cases decided thereunder would not bar carryovers in comparable situations ...
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2d Cir 9th Cir acquired affd agreement alimony amended Amoco amount apply Bank basis Burnetta capital gain cash claimed Cleanamation collateral estoppel computation contends contract corporation costs debt decedent decedent's decision deduction depreciation distribution Dreyer drilling employees entitled estate tax executors expenses fact Federal income tax fees filed gross income held included Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service issue Jobusch Judge liability loan mobile rigs mortgage notice of deficiency nunc pro tunc obligation operating loss opinion ordinary income paid parties payments percent petition petitioner petitioner's prior purposes pursuant qualify received renunciation reorganization respect Respondent determined RESPONDENT Docket respondent's rule Scifo section 483 Service shareholders shares Southland spouse statute statutory SUB plan supra Tax Court taxable taxpayer tion transfer trust United Vermont Gas Systems
Bagian yang populer
Halaman 7 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other 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, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Halaman 936 - Secretary or his delegate not to be discriminatory in favor of employees who are officers, shareholders, persons whose principal duties consist in supervising the work of other employees, or highly compensated employees; and (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.
Halaman 238 - It is a familiar rule that a thing may be within the letter of the statute and yet not within the statute, because not within its spirit, nor within the intention of its makers.
Halaman 76 - Interest upon the amount determined as a deficiency shall be assessed at the same time as the deficiency, shall be paid upon notice and demand from the collector, and shall be collected as a part of the tax, at the rate of 6 per centum per annum from the date prescribed for the payment of the tax (or, if the tax is paid in installments, from the date prescribed for the payment of the first installment) to the date the deficiency is assessed...
Halaman 670 - The legislature, therefore, declares that in its considered judgment the public good, and the general welfare of the citizens of this State require the enactment of this measure under the police powers of the State for the compulsory setting aside of unemployment reserves to be used for the benefit of persons unemployed through no fault of their own.
Halaman 421 - ... deductions shall be a full and complete discharge and acquittance of all claims and demands whatsoever for the services rendered by such person during the period covered by such payment, except as to the benefits provided under this act.
Halaman 175 - ... offenses against law, the common law, as modified and changed by the constitution and statutes of the State wherein the court having jurisdiction of such civil or criminal cause is held, so far as the same is not inconsistent with the Constitution and laws of the United States, shall be extended to and govern the said courts in the trial and disposition of the cause, and, if it is of a criminal nature, in the infliction of punishment on the party found guilty.
Halaman 392 - 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...
Halaman 452 - June 22, 1954) or in a redemption to which section 302 (a) or 303 applies, the part of such distribution which Is properly chargeable to capital account shall not be treated as a distribution of earnings and profits.
Halaman 237 - The fact is that the difficulties of so-called interpretation arise when the legislature has had no meaning at all; when the question which is raised on the statute never occurred to it; when what the judges have to do is, not to determine what the legislature did mean on a point which was present to its mind, but to guess what it would have intended on a point not present to its mind, if the point had been present.