WebJan 15, 1991 · Opinion for Cottage Savings Assn. v. Commissioner, 499 U.S. 554, 111 S. Ct. 1503, 113 L. Ed. 2d 589, 1991 U.S. LEXIS 2224 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. WebEconomic-Substance Doctrine and Subchapter C - Wachtell, Lipton ... EN English Deutsch Français Español Português Italiano Român Nederlands Latina Dansk Svenska Norsk Magyar Bahasa Indonesia Türkçe Suomi Latvian …
Recourse and Nonrecourse Debt: What Are the Federal Income …
WebJan 15, 1991 · Cottage Savings realized a tax-deductible loss because the properties it exchanged were materially different. Pp. 559-567. (a) In order to avoid the cumbersome, abrasive, and unpredictable administrative task of valuing assets annually to determine whether their value has appreciated or depreciated, 1001(a) of the Code defers the tax ... Cottage Savings made a transaction pursuant to this regulation by exchanging 90% participation interests in 252 mortgages to four other S&Ls, receiving in return 90% participation interests in 305 mortgages. All the mortgages involved in the transaction were for homes in the Greater Cincinnati region. See more Cottage Savings Association v. Commissioner, 499 U.S. 554 (1991), was an income tax case before the Supreme Court of the United States. The Court was asked to determine whether the … See more In an opinion by Justice Marshall, the Court came to three key findings: Material difference is a requirement for a disposition under §1001. Justice Marshall cited See more The emphasis in Cottage Savings on realization as an administrative requirement makes evident the capricious role that realization plays in the tax field. • If the realization requirement can be met at a very low threshold, as the decision implies, then … See more Cottage Savings Association was a savings & loan association (S&L) serving the Greater Cincinnati area. Like many other S&L's, Cottage Savings had a large number of long … See more § 1001(a) of the Internal Revenue Code requires that the tax consequences of a gain or loss in property value be deferred until it is realized by "the sale or other disposition of property". Since the transaction was certainly not a sale, the Court identified the … See more • List of United States Supreme Court cases, volume 499 • List of United States Supreme Court cases See more • Works related to Cottage Savings Association v. Commissioner of Internal Revenue at Wikisource • Text of Cottage Savings Ass'n v. Commissioner, 499 U.S. 554 (1991) is available from: Justia Library of Congress Oyez (oral argument audio) See more red chemist
Combatting Digital International Tax Crimes: Meet the New “J5"
WebPages 81 ; Ratings 100% (1) 1 out of 1 people found this document helpful; This preview shows page 45 - 47 out of 81 pages.preview shows page 45 - 47 out of 81 pages. WebOn its 1980 federal income tax return, Cottage Savings claimed a deduction for $2,447,091, which represented the adjusted difference between the face value of the participation interests that it traded and the fair market value of the participation interests that it received. WebJan 15, 1991 · On its 1980 federal income tax return, Cottage Savings claimed a deduction for $2,447,091, which represented the adjusted difference between the face value of the participation interests that it traded and the fair market value … red chenille hat