Reports of the Tax Court of the United States, Volumen117U.S. Government Printing Office, 2001 |
Otras ediciones - Ver todas
Reports of the Tax Court of the United States, Volumen108 United States. Tax Court Vista completa - 1997 |
Reports of the Tax Court of the United States, Volumen7 United States. Tax Court Vista completa - 1947 |
Reports of the Tax Court of the United States, Volumen118 United States. Tax Court Vista completa - 2002 |
Términos y frases comunes
9th Cir accrued benefit affd amended American Samoa amount applicable assessment Avdel bakery workers Brussels leaseback carryback cash payroll workers claimed collection action Combrink Commissioner compensation corporation costs decedent's deduction DeVilbiss diem allowances Emphasis added employee entitled Federal income tax gross estate gross income Guam Haas held included Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service intervenor issue Johnston Atoll Johnston Island jurisdiction Lemelson ment notice of deficiency notice of determination opinion paid parties payments penalty period peti petition petitioner petitioner filed petitioner's purposes pursuant qualified offer Quintron Rept request respect retirement route distributors Rule Sadanaga section 931 shareholder Shorthorn partnership specified liability losses spouse stare decisis Stat statute statutory subpart F substantial supra T.C. Memo Tax Court tax liability taxable taxpayer Textron tion tioner transaction travel expenses trial United voting trust wages Wildervank
Pasajes populares
Página 267 - Generally, such relationship exists when the person for whom services are performed has the right to control and direct the individual who performs the services, not only as to the result to be accomplished by the work but also as to the details and means by which that result is accomplished ; that is, an employee is subject to the will and control of the employer not only as to what shall be done but how it shall be done.
Página 102 - ... possession of the United States', and • • • "(3) If, in case of such citizen, 50 per centum or more of his gross income (computed without the benefit of this section) for such period or such part thereof was derived from the active conduct of a trade or business within a possession of the United States either on his own account or as an employee or agent of another.
Página 92 - Subsection (a) shall apply if the redemption is in complete redemption of all of the stock of the corporation owned by the shareholder.
Página 93 - Distributions of property — (a) In general. Except as otherwise provided In this chapter, a distribution of property (as defined in section 317 (a) ) made by a corporation to a shareholder with respect to its stock shall be treated in the manner provided in subsection (c).
Página 79 - For purposes of this subpart, the term "adverse party" means any person having a substantial beneficial interest in the trust which would be adversely affected by the exercise or nonexerclse of the power which he possesses respecting the trust.
Página 79 - SEC. 671. Trust income, deductions, and credits attributable to grantors and others as substantial owners. Where it is specified in this subpart that the grantor or another person shall be treated as the owner...
Página 27 - Amounts paid specifically— either as advances or reimbursements— for traveling or other bona fide ordinary and necessary expenses incurred or reasonably expected to be incurred in the business of the employer are not wages and are not subject to withholding.
Página 87 - B0 in control, then (unless paragraph (2) applies) such property shall be treated as a distribution In redemption of the stock of the corporation acquiring such stock.
Página 165 - ... the reviewing court shall decide all relevant questions of law, interpret constitutional and statutory provisions, and determine the meaning or applicability of the terms of an agency action. The reviewing court shall: 1 . compel agency action unlawfully withheld or unreasonably delayed; and 2. hold unlawful and set aside agency action, findings, and conclusions found to be: a) arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law...
Página 94 - For purposes of this section, fair market value shall be determined as of the date of the distribution. (c) Amount taxable. In the case of a distribution to which subsection (a) applies — (1) Amount constituting dividend. That portion of the distribution which is a dividend (as defined in section 316 [26 USCS § 316]) shall be included in gross income.