Reports of the U.S. Board of Tax Appeals, Volume 39U.S. Government Printing Office, 1939 - Taxation |
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Page 2
... contends that the expenditure is not deductible as an ordinary and necessary business expense ; that the partnership did not have an insurable interest in the life of the President of the United States ; and that the policies for which ...
... contends that the expenditure is not deductible as an ordinary and necessary business expense ; that the partnership did not have an insurable interest in the life of the President of the United States ; and that the policies for which ...
Page 3
... contends that continuance of the life of the President of the United States was of advantage to the business of the copartnership and that it had an insurable interest in the life of the President . In this connection , we are asked to ...
... contends that continuance of the life of the President of the United States was of advantage to the business of the copartnership and that it had an insurable interest in the life of the President . In this connection , we are asked to ...
Page 10
... contends that the trust involved , though reserv- ing income for life to the settlor , was formed in 1924 , and determinable under the Revenue Act of 1924 , and therefore was not as a matter of law made in contemplation of or intended ...
... contends that the trust involved , though reserv- ing income for life to the settlor , was formed in 1924 , and determinable under the Revenue Act of 1924 , and therefore was not as a matter of law made in contemplation of or intended ...
Page 12
... contends , the privilege of succession was not fully exer- cised by the decedent during her lifetime . Saltonstall v . Saltonstall , 276 U. S. 260 , is cited as authority . Further , we are urged that the distinction between the New ...
... contends , the privilege of succession was not fully exer- cised by the decedent during her lifetime . Saltonstall v . Saltonstall , 276 U. S. 260 , is cited as authority . Further , we are urged that the distinction between the New ...
Page 25
... contends for overassessments of $ 7,986.96 and $ 7,994.56 , respectively . An issue raised in each proceeding re- specting a credit taken for foreign taxes has been abandoned . The parties disposed of another issue by stipulating the ...
... contends for overassessments of $ 7,986.96 and $ 7,994.56 , respectively . An issue raised in each proceeding re- specting a credit taken for foreign taxes has been abandoned . The parties disposed of another issue by stipulating the ...
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Common terms and phrases
agreed amount Anglo-Chilean applied assets assignment basis beneficiary Board bonds capital cash certificate certiorari claim class A stock COMMISSIONER OF INTERNAL common stock contract corporation corpus Court decedent December December 31 decision deduction deficiency determined distribution dividends Docket employees entitled estate tax exchange executed Executors February 14 filed FINDINGS OF FACT follows fund Gershom Mott grantor Gregg County gross estate gross income Guggenheim held Helvering included income tax income tax return interest INTERNAL REVENUE Investment issue Lautaro lease liability loans loss ment Motors Securities National Bank net income nitrate old firm opinion paid parties partners partnership payable payment percent peti petitioner petitioner's preferred stock principal prior profits purchase question received respondent Revenue Act settlor shares statute stipulated stockholders supra taxable taxpayer thereof tion tioner transfer trust income trust instrument wife York
Popular passages
Page 641 - ... rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity...
Page 348 - ... or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death (1) the possession or enjoyment of, or the right to the income from, the property...
Page 371 - Amounts received under a life insurance contract paid by reason of the death of the insured, whether in a single sum or otherwise (but if such amounts are held by the insurer under an agreement to pay interest thereon, the interest payments shall be included in gross income); (2) ANNUITIES, ETC. — Amounts received (other than amounts paid by reason of the death of the insured...
Page 24 - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power...
Page 357 - INCOME. The net income of the estate or trust shall be computed in the same manner and on the same basis as in the case of an individual...
Page 241 - Where at any time the power to revest in the grantor title to any part of the corpus of the trust is vested — (1) in the grantor, either alone or in conjunction with any person not having a substantial adverse interest...
Page 790 - Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property...
Page 213 - In the case of a taxpayer, other than a corporation, only the following percentages of the gain or loss recognized upon the sale or exchange of a capital asset shall be taken into account...
Page 348 - To the extent of the amount receivable by the executor as insurance under the policies taken out by the decedent upon his own life; and to the extent of the excess over $40,000 of the amount receivable by all other beneficiaries as insurance under policies taken out by the decedent upon his own life.
Page 394 - ... (b) Interest. — All interest paid or accrued within the taxable year on indebtedness, except on indebtedness incurred or continued to purchase or carry obligations or securities (other than obligations of the United States issued after September 24, 1917, and originally subscribed for by the taxpayer) the interest upon which is wholly exempt from taxation under this title.