American Federal Tax ReportsPrentice-Hall, 2003 |
From inside the book
Results 1-3 of 78
Page 2003-514
... transactions were " sham transactions . Thus , to the extent profit motive is an element of a sham transaction , any inquiry into motive was moot in those cases , and the courts sim- ply refused to add an additional factor beyond " sham ...
... transactions were " sham transactions . Thus , to the extent profit motive is an element of a sham transaction , any inquiry into motive was moot in those cases , and the courts sim- ply refused to add an additional factor beyond " sham ...
Page 2003-1210
... transaction . Under Davis , where property with a read- ily ascertainable value is exchanged in an " arm's length " transaction for property without a readily ascertainable value , the value of the latter property is presumed to be ...
... transaction . Under Davis , where property with a read- ily ascertainable value is exchanged in an " arm's length " transaction for property without a readily ascertainable value , the value of the latter property is presumed to be ...
Page 2003-1216
... transactions in each case , Kohler contends , were virtually identical and thus the tax consequences should be the same . But if Kohler's characterization of the CMI transaction is correct , and it appears to be so , then the United ...
... transactions in each case , Kohler contends , were virtually identical and thus the tax consequences should be the same . But if Kohler's characterization of the CMI transaction is correct , and it appears to be so , then the United ...
Contents
AFTR2d Parallel Citations Tables 11 | 2003-275 |
Case Table for Volume 91 AFTR2d 51 | 2003-283 |
Income Tax Decisions | 2003-301 |
Copyright | |
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2d Cir 5th Cir 91 AFTR action affirmed AFTR 2d agreement alleged amended amount apply Appx argues argument asserts assessment attorney audit Bank Bankr Bankruptcy Court Bktcy Ct Chevron Circuit Cite as 91 claim Code Commissioner complaint Corp counsel debtor Decision for Govt deduction defendant defendant's denied determination District Judge documents employees evidence fact filed Gambones granted hearing income tax injunction interest Internal Revenue Code Internal Revenue Service IRS's issue Judicial Watch jurisdiction jury KPMG litigation ment motion for summary notice partnership party payments penalty petition Plaintiff privilege proceeding pursuant reasonable received request Rule ruptcy Section Southern Dist statute summary judgment summons Supp tar sands Tax Court tax liability Tax Reporter tax returns taxpayer tion transaction trial trucks Trustee U.S. District Court UNITED STATES DISTRICT United States Tax violation