Reports of the United States Tax Court, Volumen99United States Tax Court, 1992 |
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9th Cir actuarial assumptions additions to tax affd affg agree agreement amendment amount apply assessment assets Attorney Berg benefit Boren Steel carrybacks claim Commissioner Congress corporation costs culm banks decedent's deduction dividend docket Elektra employees enrolled actuary EOR technology ERISA estate tax excise tax exempt expenses fact farm fees Feinson filed foster care franchisee FSAA grand jury Income Tax Regs income tax return interest rate assumption Internal Revenue Code Internal Revenue Service investment issue Klingler lease liability license limitations McDonald's ment notice of deficiency operation opinion participant parties partnership items payments pension plans percent period peti petition petitioner's petitioners polygraph purchase purposes pursuant qualified reasonable received refund regulations Rept respect respondent's result retirement age Rule section 893 shareholder Stat statute subpoena supra T.C. Memo tar sands Tax Court Tax Matters Partner taxable expenditure taxpayer tion tioner transaction trust United
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Página 377 - Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.
Página 198 - The gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis provided in section 1011 for determining gain, and the loss shall be the excess of the adjusted basis provided1 in such section for determining loss over the amount realized. (b) Amount realized,. The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.
Página 264 - 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.
Página 400 - In support of this argument, taxpayers made reference to the reports of the Senate Finance Committee and the House Ways and Means Committee...
Página 321 - ... taxes assessed against local benefits of a kind tending to increase the value of the property assessed...
Página 4 - Such fair market value shall be the fair market value as of the first day of the taxable year in which such timber is cut, and shall thereafter be considered as the cost of such timber to the taxpayer for all purposes for which such cost is a necessary factor.
Página 373 - If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue...
Página 479 - ... or 2 years from the time the tax was paid, whichever of such periods expires the later, or if no return was filed by the taxpayer, within 2 years from the time the tax was paid.
Página 198 - Determination of amount of and recognition of gain or loss — (a) Computation of gain or loss. The gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis provided in section 1011 for determining gain, and the loss shall be the excess of the adjusted basis provided in such section for determining loss over the amount realized.
Página 508 - There is, of course, no more persuasive evidence of the purpose of a statute than the words by which the legislature undertook to give expression to its wishes.