dure together with forms, as amended to December 1, 2014. The
rules and forms have been promulgated and amended by the
United States Supreme Court pursuant to law, and further amend-
ed by Acts of Congress. This document has been prepared by the
Committee in response to the need for an official up-to-date docu-
ment containing the latest amendments to the rules.
For the convenience of the user, where a rule has been amended
a reference to the date the amendment was promulgated and the
date the amendment became effective follows the text of the rule.
The Committee on Rules of Practice and Procedure and the Ad-
visory Committee on the Federal Rules of Appellate Procedure,
Judicial Conference of the United States, prepared notes explain-
ing the purpose and intent of the amendments to the rules. The
Committee Notes may be found in the Appendix to Title 28, United
States Code, following the particular rule to which they relate.
The United States Tax Court is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 providing (in part) that Congress has the power to "constitute Tribunals inferior to the Supreme Court. “The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule”).”
8 Findings of Fact
19 The LILO Test Transactions20 OBB LILO20 Lease and Sublease23 End of Sublease Term25 SNCB 2 and SNCB 5 Lot 1 LILO Transactions25 Lease and Sublease28 End of Sublease Term
28 The SILO Test Transactions29 TIWAG29 Lease and Sublease33 End of Sublease Term35 Two Dortmund Transactions35 Lease and Sublease38 End of Sublease39 SNCB SILO39 Grant and Subgrant42 End of Subgrant Term
43 Tax Returns, Notices of Deficiency, and Trial43 Procedural History48 Trial
53 Opinion53 Burden of Proof53 Principal Place of Business54 Leveraged Lease Transactions54 Frank Lyon58 LILO and SILO Litigation
77 The Test Transactions78 Economic Substance79 Objective Inquiry88 Subjective Inquiry89 Substance Over Form91 OBB and SNCB LILO Transactions110 SILO Test Transactions
145 Interest Deductions
147 Original Issue Discount
149 Transaction Expenses
NOTE: NO FURTHER DISCOUNTS FOR ALREADY REDUCED SALE ITEMS.
Keywords: tax court reports, reports of the united states tax court, u.s. tax court reports, united states tax court reports, united states tax court, u.s. tax court, tax court
Attorneys, paralegals, law enforcement, court clerks, prosecutors, defendants, judges, and others involved with the U.S. Court system in relation to criminal cases may be interested in this booklet. Additionally, students pursuing criminal justice, or law degrees may be interested in these rules as they may impact their career choice(s). Lastly, all law libraries and public libraries should have a copy of this volume available for their patrons.
Other related print titles that may be of interest:
United States Code, 2012 Edition, V. 12, Title 18, Crimes and Criminal Procedure to Title 19, Customs Duties, Sections 1 to 1654 can be found here: https://bookstore.gpo.gov/products/sku/052-001-00629-1?ctid=130