§96
17 cases·1 followed·1 distinguished·15 cited—6% support
Statute Text — 26 U.S.C. §96
Statute text not available for this section.
17 Citing Cases
1055 n.5 (9th Cir. 2014), § T.C. Memo. 2012-106; Samueli v. Commissioner, 661 F.3d 399, 403 n.4 (9th Cir. 2011), aff'g in part, remanding in - 23 - p_art 132 T.C. 37 (2009); First Chi. NBD Corp. v. Commissioner, 135 F.3d 457, 460 (7th Cir. 1998), § 96 T.C. 421 (1991). B. Analysis Under the specific facts ofthis case, section 677(a)(1) and its accompanying regulations compel the conclusions that (1) IDG was the owner ofVillage and Plains in 2010 and 2012, respectively, and Gales Creek Terrace LL
Section 96(e) provides that if the election- is made, y the amount included in' gross incomeafor the taxable year of receipt-mustinot exceed the sum of the increases in gross e incom:e- forathose previous taxable years that would result from taking into account thea portion of the benefite attributable to the previous taxable