Reports of the Tax Court of the United States, Volume 108U.S. Government Printing Office, 1997 |
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Resultados 1-5 de 19
Página 126
... Texas Instruments Inc. v . Commissioner , T.C. Memo . 1992-306 ; sec . 1.451- 3 ( d ) ( 5 ) ( iii ) , Income Tax Regs . Period costs include marketing and selling expenses , distribution expenses , general and administrative expenses ...
... Texas Instruments Inc. v . Commissioner , T.C. Memo . 1992-306 ; sec . 1.451- 3 ( d ) ( 5 ) ( iii ) , Income Tax Regs . Period costs include marketing and selling expenses , distribution expenses , general and administrative expenses ...
Página 358
... Texas Instruments , Inc. v . United States , 551 F.2d 599 ( 5th Cir . 1977 ) , and adopted by this Court in Ronnen v . Commissioner , 90 T.C. 74 ( 1988 ) , is not applied to the com- puter software in issue . The test of tangibility in ...
... Texas Instruments , Inc. v . United States , 551 F.2d 599 ( 5th Cir . 1977 ) , and adopted by this Court in Ronnen v . Commissioner , 90 T.C. 74 ( 1988 ) , is not applied to the com- puter software in issue . The test of tangibility in ...
Página 363
... Texas Instruments , Inc. v . United States , 551 F.2d 599 ( 5th Cir . 1977 ) . We adopted the intrinsic value test in Ronnen v . Commissioner , 90 T.C. 74 ( 1988 ) , and held that the computer software in issue in that case was ...
... Texas Instruments , Inc. v . United States , 551 F.2d 599 ( 5th Cir . 1977 ) . We adopted the intrinsic value test in Ronnen v . Commissioner , 90 T.C. 74 ( 1988 ) , and held that the computer software in issue in that case was ...
Página 364
... Texas Instruments and by the approach of the Court of Appeals for the Ninth Circuit ( the Ninth Circuit ) in a series of cases holding that certain master sound recordings and motion pic- ture negatives were tangible personal property ...
... Texas Instruments and by the approach of the Court of Appeals for the Ninth Circuit ( the Ninth Circuit ) in a series of cases holding that certain master sound recordings and motion pic- ture negatives were tangible personal property ...
Página 365
... Texas Instruments , Inc. v . United States , supra at 611 , held that seismic data tapes and film " have intrinsic value because the seismic information thereon does not exist as property separate from the physical mani- festation " and ...
... Texas Instruments , Inc. v . United States , supra at 611 , held that seismic data tapes and film " have intrinsic value because the seismic information thereon does not exist as property separate from the physical mani- festation " and ...
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Palavras e frases frequentes
9th Cir Acme Markets affd agreement allocated amount apply ASAT asbestos assets benefits blocked deposits cancellation Circuit claim Commis Commissioner contributions Corp corporation costs Court of Appeals cruzados dealerships deduction determined docket Duskin employees escrow Exxon Federal income tax filed foreign forward contracts Frank Wheaton funds Gilson gross income Guardian Bank included Income Tax Regs income tax return intangible interest Internal Revenue Internal Revenue Code investment issue liability loans loss Lucky Stores ment Michael Ferguson Mister Donut Norwest notice of deficiency Ohanesian paid parties percent peti petitioner petitioner's PLRF Prime plan prior purchase purposes pursuant received regulations respect respondent respondent's rule Seiyo settlement Stanford Financial supra T.C. Memo tangible tax credit taxable income taxpayer Texas Instruments tion tioner trade or business transaction transfer trust United vacation pay
Passagens conhecidas
Página 495 - ... amounts collected from members for the sole purpose of making such payments and meeting expenses: (17) Teachers' retirement fund associations of a purely local character.
Página 580 - The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the provisions of this title.
Página 68 - If such section 38 property is disposed of, or otherwise ceases to be section 38 property or becomes public utility property with respect to the transferee, before the close of the estimated useful life which was taken into account in computing...
Página 421 - To the extent of any interest therein of which the decedent has at any time made a transfer...
Página 164 - If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise...
Página 275 - It merely keeps the property in an operating condition over its probable useful life for the uses for which it was acquired. Expenditures for that purpose are distinguishable from those for replacements, alterations, improvements or additions which prolong the life of the property, increase its value, or make it adaptable to a different use. The one is a maintenance charge, while the others are additions to capital investment which should not be applied against current earnings.
Página 479 - The grantor shall be treated as the owner of any portion of a trust, whether or not he is treated as such owner under section 674, whose income without the approval or consent of any adverse party is. or. in the discretion of the grantor or a nonadverse party, or both, may be— (1) Distributed to the grantor...
Página 421 - The value of the gross estate of the decedent shall be determined by including to the extent provided for in this part, the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated.
Página 129 - NET EARNINGS FROM SELF-EMPLOYMENT. — The term 'net earnings from self-employment' means the gross income derived by an individual from any trade or business carried on by such individual, less the deductions allowed...
Página 56 - States, the construction of which is initiated before promulgation of standards and regulations under this section; (3) "public vessel" means a vessel owned or bareboat chartered and operated by the United States, by a State or political subdivision thereof, or by a foreign nation, except when such vessel is engaged in commerce; (4) "United States...