Reports of the U.S. Board of Tax Appeals, Volume 24U.S. Government Printing Office, 1932 - Taxation |
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Page 21
... distribution was of the assets of the tax- payer , to its stockholders , and in complete liquidation . Even if the distribution had been made by the taxpayer , we could not hold that it was thereby left insolvent . It never paid the tax ...
... distribution was of the assets of the tax- payer , to its stockholders , and in complete liquidation . Even if the distribution had been made by the taxpayer , we could not hold that it was thereby left insolvent . It never paid the tax ...
Page 49
... distribution in 1923 , the petitioner advised the secretary of the corporation that his children each owned one - third of the stock which appeared in his name and asked that the dividend checks be made out accordingly . The secretary ...
... distribution in 1923 , the petitioner advised the secretary of the corporation that his children each owned one - third of the stock which appeared in his name and asked that the dividend checks be made out accordingly . The secretary ...
Page 89
... distribution to be made to the bene- ficiaries hereunder . 2. All of the net funds and avails realized in liquidation of said land con- tracts and properties under said trust indenture in excess of the requirements of the same and of ...
... distribution to be made to the bene- ficiaries hereunder . 2. All of the net funds and avails realized in liquidation of said land con- tracts and properties under said trust indenture in excess of the requirements of the same and of ...
Page 92
... establishment of the trust estate . These pur- poses and policies are declared to be of paramount importance in de- termining the " amount of any current distribution to be 92 ( 84 ) 24 U. S. BOARD OF TAX APPEALS REPORTS .
... establishment of the trust estate . These pur- poses and policies are declared to be of paramount importance in de- termining the " amount of any current distribution to be 92 ( 84 ) 24 U. S. BOARD OF TAX APPEALS REPORTS .
Page 93
... distribution under the terms of the indenture . All the provisions of both instru- ments with reference to the handling or investment of surplus prin- cipal funds are subordinate and incidental to this main purpose . It is also apparent ...
... distribution under the terms of the indenture . All the provisions of both instru- ments with reference to the handling or investment of surplus prin- cipal funds are subordinate and incidental to this main purpose . It is also apparent ...
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acquired agreed agreement alleged allowed Amalgamated Sugar Company amount assessment assets basis beneficiaries Board bonds capital stock cash cent Centaur Company claimed COMMISSIONER OF INTERNAL common stock computing contract corporation cost Court death debts decedent December 31 deduction depletion depreciation determined disallowed distribution dividends Docket Executors expenses February 28 filed FINDINGS OF FACT follows gifts inter vivos gross income held included income tax income-tax return interest INTERNAL REVENUE inventory invested capital issue January June 30 lease lessee lessor liability Loew's Incorporated loss Lumber March ment net income operating opinion paid par value parties partnership payment period peti petitioner petitioner contends petitioner's preferred stock prior proceeding profits purchase Railroad real estate received respect respondent respondent's Revenue Act Robert Pitman Rule 50 shares sold statute stipulated stockholders supra surplus taxable income taxpayer thereof thereto tion tioner transfer trust wife