§232

21 cases·1 distinguished·20 cited

Statute text not available for this section.

21 Citing Cases

at 826, 831–32, the TRA 1986 §§ 232, 701(c)(2), 1275(c)(4), 1879(b), 100 Stat.

Edwin L. Gage & Elaine R. Gage, Petitioners T.C. Memo. 2023-47 · 2023

2 An identity-of-interest “is any relationship based on family ties or financial interests between or among two or more entities involved in a project-related transaction which reasonably gives rise to a presumption that the entities may not operate at arms-length.” HUD, Healthcare Mortgage Insurance Program Section 232 of the National Housing Act: A HUD Handbook § I, Ch.

sident aliens, and which has only one class of stock. Sec. 1361(b)(1). Before January 1, 2005, while Western Funding Group was active, the statute capped the number of shareholders at 75. See American Jobs Creation Act of 2004, Pub. L. No. 108- 357, sec. 232, 118 Stat. at 1434. Sec. 1362(a)(1) allows a small business corporation to elect S corporation status for tax purposes. - 103 - [*103] businesses’ accounts receivable, or receiving factoring fees--would flow through to the tax-exempt ESOPs.

sident aliens, and which has only one class of stock. Sec. 1361(b)(1). Before January 1, 2005, while Western Funding Group was active, the statute capped the number of shareholders at 75. See American Jobs Creation Act of 2004, Pub. L. No. 108- 357, sec. 232, 118 Stat. at 1434. Sec. 1362(a)(1) allows a small business corporation to elect S corporation status for tax purposes. - 103 - [*103] businesses’ accounts receivable, or receiving factoring fees--would flow through to the tax-exempt ESOPs.

sident aliens, and which has only one class of stock. Sec. 1361(b)(1). Before January 1, 2005, while Western Funding Group was active, the statute capped the number of shareholders at 75. See American Jobs Creation Act of 2004, Pub. L. No. 108- 357, sec. 232, 118 Stat. at 1434. Sec. 1362(a)(1) allows a small business corporation to elect S corporation status for tax purposes. - 103 - [*103] businesses’ accounts receivable, or receiving factoring fees--would flow through to the tax-exempt ESOPs.

sident aliens, and which has only one class of stock. Sec. 1361(b)(1). Before January 1, 2005, while Western Funding Group was active, the statute capped the number of shareholders at 75. See American Jobs Creation Act of 2004, Pub. L. No. 108- 357, sec. 232, 118 Stat. at 1434. Sec. 1362(a)(1) allows a small business corporation to elect S corporation status for tax purposes. - 103 - [*103] businesses’ accounts receivable, or receiving factoring fees--would flow through to the tax-exempt ESOPs.

sident aliens, and which has only one class of stock. Sec. 1361(b)(1). Before January 1, 2005, while Western Funding Group was active, the statute capped the number of shareholders at 75. See American Jobs Creation Act of 2004, Pub. L. No. 108- 357, sec. 232, 118 Stat. at 1434. Sec. 1362(a)(1) allows a small business corporation to elect S corporation status for tax purposes. - 103 - [*103] businesses’ accounts receivable, or receiving factoring fees--would flow through to the tax-exempt ESOPs.

Marvin S. & Thelma S. Kerzner, Petitioner T.C. Memo. 2009-76 · 2009

In 1986 petitioners formed the Highland Court Associates partnership (HCA) and HCI, an S corporation within the meaning of section 1361(a) .

232(a), 98 Stat. 2991, and is effective for taxable years beginning after Oct. 30, 1984. Under a provision now repealed, taxpayers who elected to capitalize advertising expenditures in computing their liability under the now defunct wartime excise profits taxes had to follow a consistent practice for subsequent expenditures. Sec. 263(b) (repea

Eldon R. & Susan M. Kenseth, Petitioner 114 T.C. No. 26 · 2000
Foerderer v. Commissioner 16 T.C. 956 · 1951
Canfield v. Commissioner 7 T.C. 944 · 1946
Fischer v. Commissioner 5 T.C. 507 · 1945
United States v. Christopher Arthur · Cir.
Atlantic Fish Spotters Ass'n v. Daley 205 F.3d 488 · Cir.
United States v. Musso 914 F.3d 26 · Cir.
Taproot Administrative Services, Inc. v. Commissioner 679 F.3d 1109 · Cir.