In a previous decision, the Tax Court stated that West Covina had not provided sufficient substantiation that any fees were allocable
entirely to inventory (West Covina Motors, Inc.
The other piece of potentially good news is that even though Revenue Procedure 2007-53 clearly prohibits treating amounts allocable
to cooperative advertising as trade discounts, a portion of the advance may not have to be carved out for cooperative advertising if the refund feature depends solely on fulfilling the purchase commitment.
199-2(e)(1); (12) and then (2) determine the portion of the above amount that is properly allocable
to DPGR using Temp.
The Company reported a quarterly operating loss and a net loss allocable
to common shareholders of $390,000 and $395,000, respectively, in the fourth quarter of 2009 compared to an operating loss and a net loss allocable
to common shareholders of $484,000 and $448,000, respectively, in the comparable year ago period.
For a partnership or S corporation (under the pre-TIPRA law), the W-2 wages allocable
to a partner or owner were limited to the lesser of the partner/owner's allocable
share of wages or two times the applicable Sec.
Recent statutory changes limit the W-2 wages that may be counted in the overall W-2 wage limitation to those properly allocable
to DPGR and expand the wages that may be allocated to owners from passthrough entities.
The crux of the issue is whether environmental cleanup costs are properly allocable
After allocating the basis and the amount realized between these portions, Bob determines that $12,000 of the gain is allocable
to the residential portion and $6,000 is allocable
to the rental portion.
Section 163(h)(2)(A) defines this term as any interest allowable as a deduction, other than that paid or accrued on debt "properly allocable
to a trade or business" (other than the trade or business of being an employee).
NYSE:LTC) released results of operations for the three and twelve months ended December 31, 2009 and announced that net income allocable
to common stockholders for the fourth quarter was $7.
To comply with this requirement, the partnership must determine whether it has any foreign partners, determine the partnership's ECTI allocable
to each foreign partner, compute the Sec.
2) expenses directly allocable
to the receipts, and