Reports of the Tax Court of the United States, Volume 118U.S. Government Printing Office, 2002 |
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Página 32
... Burndy - US ( B - US ) , a predecessor of Framatome Connectors USA , Inc. , one of the petitioners ( Ps ) , owned 50 percent of the stock of Burndy - Japan ( B - J ) . Furukawa Electric Co. ( F ) and Sumitomo Electrical Indus . , Ltd ...
... Burndy - US ( B - US ) , a predecessor of Framatome Connectors USA , Inc. , one of the petitioners ( Ps ) , owned 50 percent of the stock of Burndy - Japan ( B - J ) . Furukawa Electric Co. ( F ) and Sumitomo Electrical Indus . , Ltd ...
Página 33
... Burndy - Japan 36 1. Formation 36 2. Agreements Between Burndy - US , Furukawa , and Sumitomo From 1962 to 1973 37 3. 1973 Basic Agreement 38 4. Burndy - Japan's Presidents and Board of Directors ...... 5. 1988 Technical Assistance ...
... Burndy - Japan 36 1. Formation 36 2. Agreements Between Burndy - US , Furukawa , and Sumitomo From 1962 to 1973 37 3. 1973 Basic Agreement 38 4. Burndy - Japan's Presidents and Board of Directors ...... 5. 1988 Technical Assistance ...
Página 34
... Burndy - Japan Ltd. ( Burndy - Japan ) was a con- trolled foreign corporation ( CFC ) of Burndy Corp. ( Burndy- US ) 1 in 1992. We hold that it was not because Burndy - US did not own more than 50 percent of the voting power of Burndy ...
... Burndy - Japan Ltd. ( Burndy - Japan ) was a con- trolled foreign corporation ( CFC ) of Burndy Corp. ( Burndy- US ) 1 in 1992. We hold that it was not because Burndy - US did not own more than 50 percent of the voting power of Burndy ...
Página 35
... Burndy - US ( described next ) and its subsidiaries , which manufactured electrical and electronic connectors . 2 ... Japan from 1963 to 1980 ; and Theodore York ( York ) , a Burndy - US employee from 1964 to 1994 , the general man- ager ...
... Burndy - US ( described next ) and its subsidiaries , which manufactured electrical and electronic connectors . 2 ... Japan from 1963 to 1980 ; and Theodore York ( York ) , a Burndy - US employee from 1964 to 1994 , the general man- ager ...
Página 36
... Japan . Sumitomo had annual sales of $ 5 to $ 8 billion in the years in issue . Furukawa's sales were slightly less ... Burndy - Japan 1. Formation Burndy - US wanted to enter the Japanese market in the early 1960s . To do so , Burndy ...
... Japan . Sumitomo had annual sales of $ 5 to $ 8 billion in the years in issue . Furukawa's sales were slightly less ... Burndy - Japan 1. Formation Burndy - US wanted to enter the Japanese market in the early 1960s . To do so , Burndy ...
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Palavras e frases frequentes
affd agreement alternative minimum tax amount Appeals officer apply assessment assets Beech Trucking benefit Blonien Burndy-Japan Burndy-US Caracci claim Clinpath stock Commissioner computing corporation deduction distribution documents EAPR election employees Estate fair market value Farm Federal income tax filed Finley Kumble Framatome Furukawa and Sumitomo Galena airport gross income home health Income Tax Regs income tax return interest expense interest income Internal Revenue Internal Revenue Code issue jurisdiction Leasing legislative history manufactured ment minimum tax notice of deficiency paid parties partner partnership percent peti petition petitioner's Petitioners contend Puerto Rico purposes pursuant regulations reimbursement Rept respect respondent's Revenue Procedures Rule shareholders shares sioner Sta-Home tax-exempt entities statute statutory stipulated summary judgment Sun Shipping supra T.C. Memo Tate & Lyle Tax Court tax liability taxable income taxpayer tion trade or business transfer Treeco United video games WHTC
Passagens conhecidas
Página 179 - provides: 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 * * * Thus,
Página 341 - Income Tax Regs. 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 the relevant facts. Sec. 1.170Al(c)(2), Income Tax Regs.
Página 100 - "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 to sell and both having reasonable knowledge of relevant facts.'" United States v. Cartwright, 411 US
Página 97 - the price at which 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 the relevant facts". United States v. Cartwright, 411 US 546, 551
Página 316 - 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 to sell and both having reasonable knowledge of relevant facts.
Página 273 - When an act of Congress is appropriately challenged in the courts as not conforming to the constitutional mandate the judicial branch of the Government has only one duty,—to lay the article of the Constitution which is invoked beside the statute which is challenged and to decide
Página 3 - SEC. 38. GENERAL BUSINESS CREDIT. (a) ALLOWANCE OF CREDIT.—There shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the sum of— (1) the business credit carryforwards carried to such taxable year, (2) the amount of the current year business credit, plus (3) the business credit
Página 309 - treaty and statute relate to the same subject, the courts will always endeavor to construe them so as to give effect to both, if that can be done without violating the language of either; but if the two are inconsistent, the one last in date will control the other, * * * [Whitney v. Robertson,
Página 85 - No gain or loss shall be recognized to a corporation if such corporation is a party to a reorganization and exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
Página 169 - In making the foregoing determinations, the court shall review the whole record or those parts of it cited by a party, and due account shall be taken of the rule of prejudicial error. [Emphasis added.]