§177 — Repealed. Pub. L. 99–514, title II, § 241(a), Oct. 22, 1986, 100 Stat. 2181]
22 cases·1 followed·4 distinguished·1 questioned·16 cited—5% support
Statute Text — 26 U.S.C. §177
[§ 177. Repealed. Pub. L. 99–514, title II, § 241(a), Oct. 22, 1986, 100 Stat. 2181] Section, added June 29, 1956, ch. 464, § 4(a), 70 Stat. 406; amended Oct. 4, 1976, Pub. L. 94–455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834, related to deductions for trademark and trade name expenditures. Statutory Notes and Related Subsidiaries Effective Date of RepealPub. L. 99–514, title II, § 241(c), Oct. 22, 1986, 100 Stat. 2181, provided that: “(1) In general.—Except as provided in paragraph (2), the amendments made by this section [amending sections 312 and 1016 of this title and repealing this section] shall apply to expenditures paid or incurred after December 31, 1986. “(2) Transitional rule.—The amendments made by this section shall not apply to any expenditure incurred—“(A) pursuant to a binding contract entered into before March 2, 1986, or “(B) with respect to the development, protection, expansion, registration, or defense of a trademark or trade name commenced before March 2, 1986, but only if not less than the lesser of $1,000,000 or 5 percent of the aggregate cost of such development, protection, expansion, registration, or defense has been incurred or committed before such date. The preceding sentence shall not apply to any expenditure with respect to a trademark or trade name placed in service after December 31, 1987.”
22 Citing Cases
Unlike DEFRA section 177(d)(2), both of those enactments provided a fair market value basis for purposes - 22 - of determining both gain and loss.
Given this special circumstance, we do not find the cases involving core deposits distinguishable for the reason that respondent claims. It follows from our previous Opinion regarding the application of DEFRA section 177(d)(2)(A)(ii) that petitioner’s failure to establish a “cost basis” does not prevent it from claiming a higher fair market value basis in its favorable financing.
ng Act of 1970, Pub. L. 91-351, title III (Federal Home Loan Mortgage Corporation Act), 84 Stat. 451. Petitioner was originally exempt from Federal income taxation. However, Congress repealed petitioner’s Federal income tax exemption status in DEFRA section 177. Pursuant to this act, petitioner became subject to Federal income taxation, effective January 1, 1985. The question we must decide in this Opinion involves a determination of petitioner’s basis for amortizing intangibles that it allegedl
person who dominates a party or when, because oftheir relationship, a partyjustifiably assumes the person won't do anything against his welfare. Chai v. Commissioner, T.C. Memo 2011-273, 2011 WL 5600287, at *2; see also 1 Restatement, Contracts 2d, sec. 177(1) (1981). The problem with this argument is that E&Y wasn't Kalkhoven, Pettit, Esrey, or LeMay's only adviser and they all had ample reason to question E&Y long before 2004. In 2000--long before Bolton signed the 2004 extension--Esrey and Le
person who dominates a party or when, because oftheir relationship, a partyjustifiably assumes the person won't do anything against his welfare. Chai v. Commissioner, T.C. Memo 2011-273, 2011 WL 5600287, at *2; see also 1 Restatement, Contracts 2d, sec. 177(1) (1981). The problem with this argument is that E&Y wasn't Kalkhoven, Pettit, Esrey, or LeMay's only adviser and they all had ample reason to question E&Y long before 2004. In 2000--long before Bolton signed the 2004 extension--Esrey and Le
Even if we assume that Beer had the requisite domination . Over or relation to petitioner, petitioner has failed to allege facts sufficient, to show that Beer.used unfair persuasion to induce his assent to the consents., The ultimate question with unfair persuasion is whether the party's assent was produced by means that seriously im
709. P adopted the accrual method of accounting for its first taxable year commencing Jan. 1, 1985. Before that date, P acquired certain mortgages that were in default. Interest accrued on each of those mortgages from the date of acquisition up to Jan. 1, 1985. At various points after Jan. 1, 1985, P foreclosed the mortgages on t
709. P adopted the accrual method of accounting for its first taxable year commencing Jan. 1, 1985. Before that date, P acquired certain mortgages that were in default. Interest accrued on each of those mortgages from the date of acquisition up to Jan. 1, 1985. At various points after Jan. 1, 1985, P foreclosed the mortgages on t