Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
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Resultados 1-5 de 72
Página xiv
... Congress , with Treasury and IRS offi- cials , and with members of ABA Taxation Section to change the status of the Tax Court to a full - fledged court under Arti- cle I of the Constitution . That became part of the Tax Reform Act of ...
... Congress , with Treasury and IRS offi- cials , and with members of ABA Taxation Section to change the status of the Tax Court to a full - fledged court under Arti- cle I of the Constitution . That became part of the Tax Reform Act of ...
Página 13
... Congress to have only those items that are more appropriately determined at the partnership level constitute the subject of a partnership - level proceeding . See secs . 6221 , 6231 ( a ) ( 3 ) ; H. Conf . Rept . 97-760 , supra at 600 ...
... Congress to have only those items that are more appropriately determined at the partnership level constitute the subject of a partnership - level proceeding . See secs . 6221 , 6231 ( a ) ( 3 ) ; H. Conf . Rept . 97-760 , supra at 600 ...
Página 28
... Congress . See U.S. Const . , art . VI , sec . 1 , cl . 2. A treaty is to be liberally construed to give effect to the purpose which animates it . See United States v . Stu- art , 489 U.S. 353 , 368 ( 1989 ) ; Bacardi Corp. of Am . v ...
... Congress . See U.S. Const . , art . VI , sec . 1 , cl . 2. A treaty is to be liberally construed to give effect to the purpose which animates it . See United States v . Stu- art , 489 U.S. 353 , 368 ( 1989 ) ; Bacardi Corp. of Am . v ...
Página 29
... Congress " , Menomi- nee Tribe v . United States , 391 U.S. 404 , 413 ( 1968 ) ( quoting Pigeon River Co. v . Cox Co. , 291 U.S. 138 , 160 ( 1934 ) ) ; see also Estate of Burghardt v . Commissioner , 80 T.C. 705 , 713 ( 1983 ) , affd ...
... Congress " , Menomi- nee Tribe v . United States , 391 U.S. 404 , 413 ( 1968 ) ( quoting Pigeon River Co. v . Cox Co. , 291 U.S. 138 , 160 ( 1934 ) ) ; see also Estate of Burghardt v . Commissioner , 80 T.C. 705 , 713 ( 1983 ) , affd ...
Página 43
... Congress provided as follows : SEC . 702. INCOME AND CREDITS OF PARTNER . ( c ) GROSS INCOME OF A PARTNER . - In any case where it is necessary to determine the gross income of a partner for purposes of this title [ i.e. , title 26 ...
... Congress provided as follows : SEC . 702. INCOME AND CREDITS OF PARTNER . ( c ) GROSS INCOME OF A PARTNER . - In any case where it is necessary to determine the gross income of a partner for purposes of this title [ i.e. , title 26 ...
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