 Whether the partnership or a partner individually has a business purpose for the allocation; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners...  Tax Treatment of Thrift Partnership: Joint Hearing Before the Subcommittee ... - 9 페이지저자: United States. Congress. Senate. Committee on Finance. Subcommittee on Taxation and Debt Management - 1982 - 152 페이지전체보기 - 도서 정보
 | 1960 - 880 페이지
...allocation; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners'...income or loss independently of tax consequences; whether related items of income, gain, loss, deduction, or credit from the same source are subject... | |
 | 1973 - 444 페이지
...allocation; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners'...income or loss independently of tax consequences; whether related items of income, gain, loss, deduction, or credit from the same source are subject... | |
 | United States. Internal Revenue Service - 1968 - 938 페이지
...allocation ; and whether the allocation has substantial economic effect, that is, whether the allocation may actually affect the dollar amount of the partners'...income or loss independently of tax consequences. Accordingly, the provisions of the partnership agreement to allocate the intangible drilling and development... | |
 | 1961 - 566 페이지
...allocation; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners'...income or loss independently of tax consequences; whether related items of income, gain, loss, deduction, or credit from the same source are subject... | |
 | United States. Tax Court - 1983 - 1248 페이지
...allocation; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners'...income or loss independently of tax consequences; whether related items of income, gain, loss, deduction, or credit from the same source are subject... | |
 | United States. Tax Court - 1985 - 1410 페이지
...allocation; whether the allocation has 'substantial economic eflect', that is, whether the allocation may actually affect the dollar amount of the partners' shares of the total partnership income or lose independently of tax consequences; whether related items of income, gain, loss, deduction, or... | |
 | United States. Tax Court - 1970 - 1228 페이지
...than a tax-avoidance purpose. According to the regulations, an allocation has economic effect if it "may actually affect the dollar amount of the partners' shares of the "We recognize that petitioners had more money Invested in the partnership than the Crisafis and that... | |
 | United States. Tax Court - 1971 - 1242 페이지
...than a tax-avoidance purpose. According to the regulations, an allocation has economic effect if it "may actually affect the dollar amount of the partners' shares of the • We recognize that petitioners had more money invested in the partnership than the Crlsafls and... | |
 | United States. Tax Court - 1974 - 918 페이지
...allocation ; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners' shares of the total partnership iucome or loss independently of tax consequences; whether related items of income, gain, loss, deduction,... | |
 | 1966 - 404 페이지
...allocation; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners'...income or loss independently of tax consequences; whether related items of income, gain, loss, deduction, or credit from the same source are subject... | |
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