Reports of the United States Tax Court, Volume 81United States Tax Court, 1984 - Government publications |
From inside the book
Results 1-5 of 97
Page 12
... exchanges from a guest tele- phone located just to the right of the cashier's cage from which they were able to gain an ... exchange observed by the revenue agents occurred at the far right window of the cage . To avoid detection , the ...
... exchanges from a guest tele- phone located just to the right of the cashier's cage from which they were able to gain an ... exchange observed by the revenue agents occurred at the far right window of the cage . To avoid detection , the ...
Page 14
... exchanges from a distance . The exchanges took place in plain view at the cashier's cage located in a public area ... exchange indicates that any problems the agents experienced in their attempts to count the " On those few days when ...
... exchanges from a distance . The exchanges took place in plain view at the cashier's cage located in a public area ... exchange indicates that any problems the agents experienced in their attempts to count the " On those few days when ...
Page 15
... exchange took place . The revenue agent indicated he was unable to count all of the racks , and significantly , the value of his count was substantially lower than the amount he observed on the toke cutters ' yellow sheet of paper . 13 ...
... exchange took place . The revenue agent indicated he was unable to count all of the racks , and significantly , the value of his count was substantially lower than the amount he observed on the toke cutters ' yellow sheet of paper . 13 ...
Page 16
... exchange of tokes at the cashier's cage provided the revenue agents a unique opportuni- ty to determine the amount of tokes received by the dealers on a particular day . Supplemented by records of dealers ' work schedules obtained from ...
... exchange of tokes at the cashier's cage provided the revenue agents a unique opportuni- ty to determine the amount of tokes received by the dealers on a particular day . Supplemented by records of dealers ' work schedules obtained from ...
Page 78
... exchange for cash and a contingent agreement by N.V.T.H. to pay to Company up to $ 78,500 of the profit on the townhouses . Finally , on the same date , Zappo and Murphy signed a guarantee agreement guaranteeing that Company would ...
... exchange for cash and a contingent agreement by N.V.T.H. to pay to Company up to $ 78,500 of the profit on the townhouses . Finally , on the same date , Zappo and Murphy signed a guarantee agreement guaranteeing that Company would ...
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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 decision deduction determined distribution dividend docket earnings and profits employees estate tax exempt 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 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 744 - ... 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 120 - If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance, the wife's gross income includes periodic payments (whether or not made at regular intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, in discharge of) a legal obligation which, because of the marital or family relationship, is imposed on or incurred by the husband under the decree or under a written instrument incident...
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 993 - If, however, an intangible asset acquired through capital outlay is known from experience to be of value in the business or in the production of income for only a limited period, the length of which can be estimated from experience with reasonable certainty...
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 467 - Stock owned, directly or indirectly, by or for a corporation, partnership, estate, or trust, shall be considered as being owned proportionately by or for its shareholders, partners, or beneficiaries...
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 679 - A limited partner shall not become liable as a general partner unless, in addition to the exercise of his rights and powers as a limited partner, he takes part in the control of the business.
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...