§1421

DIST. Edward A. Robinson, III & Diana R. Robinson, Petitioners 119 T.C. No. 4 · 2002

Section 1421(b) of the Finance Committee’s amendment revised section 163(d) but, unlike the House-passed bill, left that Code provision as one dealing with investment interest. Section 1421(a) of the Finance Committee’s amendment proposed a new section 163(h), which provided in pertinent part as follows: SEC.

Robinson v. Commissioner 119 T.C. 44 · 2002

1421 (as passed by the Senate), 132 Cong. Rec. S8921 (June 26, 1986)). We make these observations because of the apparent focus on the question of whether interest paid in respect of an individual’s Federal income tax liability is a “personal obligation”. See Miller v. United States, 65 F.3d at 691, stating: that an individual’s income tax lia

Sandra G. Cooper, Petitioner and The Government of the United States Virgin Islands, Intervenor, Petitioners · 2015

1421i(d)(1) (1964)). - 12 - [*12] The provisions applicable for 2002 and 2003 under which individuals file territorial income tax returns and pay tax in the Virgin Islands were enacted as part ofthe Tax Reform Act of 1986 (TRA), Pub. L. 99-514, sec. 1274(a), 100 Stat. 2596, and amended in the Technical and Miscellaneous Revenue Act of 1988, P

Barry P. Cooper, Petitioner and The Government of the United States Virgin Islands, Intervenor, Petitioners · 2015

1421i(d)(1) (1964)). - 12 - [*12] The provisions applicable for 2002 and 2003 under which individuals file territorial income tax returns and pay tax in the Virgin Islands were enacted as part ofthe Tax Reform Act of 1986 (TRA), Pub. L. 99-514, sec. 1274(a), 100 Stat. 2596, and amended in the Technical and Miscellaneous Revenue Act of 1988, P

Arthur I. Appleton, Jr. , Petitioner and The Government of the United States Virgin Islands, Intervenor, Petitioners 135 T.C. No. 23 · 2010

1421i(d) (1) (1964)). The provisions applicable for 2002, 2003, and 2004, under which individuals file income tax returns and pay tax in the Virgin Islands, were enacted as part of the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1274(a), 100 Stat. 2596, and amended in the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, sec 1

Appleton v. Commissioner 135 T.C. 461 · 2010

1421i(d)(1) (1964)). The provisions applicable for 2002, 2003, and 2004 under which individuals file income tax returns and pay tax in the Virgin Islands were enacted as part of the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1274(a), 100 Stat. 2596, and amended in the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, sec 1012

Joseph D. Specking, Petitioner 117 T.C. No. 9 · 2001

1421 (1994); or the Commonwealth of the Northern Mariana Islands (CNMI), see Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America, Pub. L. 94-241, sec. 1005(b), 90 Stat. 263, 278 (1976), current version at 48 U.S.C. sec. 1801 (1994); Trusteeship Agreement for the Former Japan

Eric N. Umbach, Petitioner 117 T.C. No. 9 · 2001

1421 (1994); or the Commonwealth of the Northern Mariana Islands (CNMI), see Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America, Pub. L. 94-241, sec. 1005(b), 90 Stat. 263, 278 (1976), current version at 48 U.S.C. sec. 1801 (1994); Trusteeship Agreement for the Former Japan

Mazen Shweika v. Dep't of Homeland Security 723 F.3d 710 · Cir.

Estate of McAlpine v. Commissioner 96 T.C. 134 · 1991

Estate of Merwin v. Commissioner 95 T.C. 168 · 1990

Estate of Doherty v. Commissioner 95 T.C. 446 · 1990

McDonald v. Commissioner 89 T.C. 293 · 1987

Rea Paeste v. Government of Guam 798 F.3d 1228 · Cir.

Preece v. Commissioner 95 T.C. 594 · 1990

Estate of Johnson v. Commissioner 89 T.C. 127 · 1987

Frontier Savings Ass'n & Subsidiaries v. Commissioner 87 T.C. 665 · 1986

Angerhofer v. Commissioner 87 T.C. 814 · 1986

Bayley v. Commissioner 69 T.C. 234 · 1977

Birdman v. Office of the Governor 677 F.3d 167 · Cir.

SEC v. Hallam · Cir.

21 Citing Cases