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Agency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.
United States Tax CourtAgency decision · Agency decision
Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.
United States Tax CourtAgency decision · Agency decision
Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.
United States Tax CourtAgency decision · Agency decision
Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … Burnet, 286 U.S. 417 (1932).
United States Tax CourtT . C . Summary Opinion 2010 -141
Agency decision · Agency decision
, 84 Helvering, 292 U.S. 435, Inc. v … - 6 sustain respondent's denial of petitioner's claimed deduction for a cash charitable contribution of $423.
United States Tax CourtAgency decision · Agency decision
Rul. 69-482, 1969-2 C.B. 164, is that these payments are capital gains; we therefore treat respondent's position in Rev. … Rul. 69-482, supra, has no application in this case. We find that the essential facts of Poole v.
United States Tax CourtAgency decision · Agency decision
Rul. 69-482, 1969-2 C.B. 164, is that these payments are capital gains; we therefore treat respondent's position in Rev. … Rul. 69-482, supra, has no application in this case. We find that the essential facts of Poole v.
United States Tax CourtAgency decision · Agency decision
U.S. … First Security Bank, 405 U.S. 394, 405 (1972) (power at issue under section 482 does not include the power to force a subsidiary to violate the law).
United States Tax CourtAgency decision · Agency decision
Sec. 482; Hospital Corp. of America v. Commissioner, 81 T.C. 520, 592 (1983). … Thus if a U.S. corporation transfers earnings and profits offshore through improperly valued intercompany transactions, section 482 provides a means whereby the Commissioner may recharacterize the 9
United States Tax CourtAgency decision · Agency decision
On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.
United States Tax CourtAgency decision · Agency decision
On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.
United States Tax CourtAgency decision · Agency decision
P, a U.S. corporation, does business in Mexico through a branch (Licensee). … This dispute conceivably may affect the merits of the section 482 adjustments that the IRS has proposed.
United States Tax CourtAgency decision · Agency decision
P, a U.S. subsidiary of F, is a film processing company. … (CIHI), are wholly owned U.S. subsidiaries of petitioner.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
P, a U.S. subsidiary of F, is a film processing company. … (CIHI), are wholly owned U.S. subsidiaries of petitioner.
United States Tax Court
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