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Reports of the United States Tax Court

Reports of the United States Tax Court PDF Author: United States. Tax Court
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1144

Book Description


Reports of the United States Tax Court

Reports of the United States Tax Court PDF Author: United States. Tax Court
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1144

Book Description


Reports of the Tax Court of the United States

Reports of the Tax Court of the United States PDF Author: United States. Tax Court
Publisher:
ISBN:
Category : Law reports, digests, etc
Languages : en
Pages : 1264

Book Description


Reports of the Tax Court of the United States

Reports of the Tax Court of the United States PDF Author: United States. Tax Court
Publisher:
ISBN:
Category : Law reports, digests, etc
Languages : en
Pages : 1264

Book Description
Final issue of each volume includes table of cases reported in the volume.

Reports of the United States Tax Court

Reports of the United States Tax Court PDF Author: United States. Tax Court
Publisher:
ISBN:
Category : Law reports, digests, etc
Languages : en
Pages :

Book Description


Reports of the United States Tax Court

Reports of the United States Tax Court PDF Author: United States. Tax Court
Publisher: Government Printing Office
ISBN: 9780160875946
Category : Taxation
Languages : en
Pages : 340

Book Description


Reports of Tax Court of the United States

Reports of Tax Court of the United States PDF Author: Mary T. Pittman
Publisher:
ISBN: 9780160037764
Category :
Languages : en
Pages : 1440

Book Description


Reports of the United States Tax Court, Volume 126, January 1, 2006 to June 30, 2006

Reports of the United States Tax Court, Volume 126, January 1, 2006 to June 30, 2006 PDF Author:
Publisher: Government Printing Office
ISBN: 9780160876035
Category : Business & Economics
Languages : en
Pages : 388

Book Description
Within each case, a briefing of the original petition with the Docket Number and date of file is stated followed by Opinion, Background, Tax Court Petition, Respondent's Motion, Petitioner's Motion, Amended Petition (if applicable), Discussion includes statuary language and former petitioners' cases, if applicable, and allegations, motions, followed by conclusion. For a list of cases found in this volume, please refer to the Table of Contents that has a listing of Cases

Reports of the United States Tax Court

Reports of the United States Tax Court PDF Author: U S Government Printing Office
Publisher:
ISBN: 9780160958434
Category :
Languages : en
Pages :

Book Description
Reports of the United States Tax Court Volume 150 January 1, 2018 to June 30, 2018

Reports of the United States Tax Court, V. 146, January 1, 2016 to June 30, 2016

Reports of the United States Tax Court, V. 146, January 1, 2016 to June 30, 2016 PDF Author: Sheila A. Murphy
Publisher: Government Printing Office
ISBN: 9780160937538
Category : Law
Languages : en
Pages : 268

Book Description
Reports of the United States Tax Court Volume 146 January 1, 2016 to June 30, 2016.

Reports of United States Tax Court, V. 141, July 1, 2013, to December 31, 2013

Reports of United States Tax Court, V. 141, July 1, 2013, to December 31, 2013 PDF Author: Government Publications Office
Publisher: Government Printing Office
ISBN: 9780160926464
Category :
Languages : en
Pages : 608

Book Description
Volume of the United States Tax Court Reports containing case abstracts and opinions of the court regarding cases between July 1, 2013 December 31, 2013. Cases in each volume are listed in the prefatory table. The United States Tax Court is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 providing (in part) that Congress has the power to "constitute Tribunals inferior to the Supreme Court. “The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule”).” Contents 8 Findings of Fact 8 Background 8 John Hancock’s History9 Investment Process and Review10 Leasing10 LILO and SILO Transactions 10 Basic Structure 15 History 17 Due Diligence 18 The Hoosier Transaction 19 The LILO Test Transactions 20 OBB LILO20 Lease and Sublease23 End of Sublease Term25 SNCB 2 and SNCB 5 Lot 1 LILO Transactions25 Lease and Sublease28 End of Sublease Term 28 The SILO Test Transactions 29 TIWAG29 Lease and Sublease33 End of Sublease Term35 Two Dortmund Transactions35 Lease and Sublease38 End of Sublease39 SNCB SILO39 Grant and Subgrant42 End of Subgrant Term 43 Tax Returns, Notices of Deficiency, and Trial 43 Procedural History48 Trial 53 Opinion 53 Burden of Proof53 Principal Place of Business54 Leveraged Lease Transactions54 Frank Lyon58 LILO and SILO Litigation 77 The Test Transactions 78 Economic Substance79 Objective Inquiry88 Subjective Inquiry89 Substance Over Form91 OBB and SNCB LILO Transactions110 SILO Test Transactions 145 Interest Deductions 147 Original Issue Discount 149 Transaction Expenses 149 Conclusion NOTE: NO FURTHER DISCOUNTS FOR ALREADY REDUCED SALE ITEMS. Keywords: tax court reports, reports of the united states tax court, u.s. tax court reports, united states tax court reports, united states tax court, u.s. tax court, tax court