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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 : Government publications
Languages : en
Pages :

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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 : Government publications
Languages : en
Pages :

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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
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ISBN:
Category : Law reports, digests, etc
Languages : en
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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:
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Category : Taxation
Languages : en
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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 : Taxation
Languages : en
Pages :

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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 : 263

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

Reports of the United States Tax Court

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

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Book Description


Reports of the United States Tax Court, Volume 139, July 1, 2012, to December 31, 2012

Reports of the United States Tax Court, Volume 139, July 1, 2012, to December 31, 2012 PDF Author: Sheila A. Murphy
Publisher: Government Printing Office
ISBN: 9780160922756
Category : Business & Economics
Languages : en
Pages : 268

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Book Description
Each volume in this series contains the case abstracts and opinions proffered by the court within a given time period. Cases in each volume are listed in the prefatory table.

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 : Law
Languages : en
Pages : 603

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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

Tax Court Reported Decisions

Tax Court Reported Decisions PDF Author: United States. Tax Court
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages :

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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 :

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