Reports of the U.S. Board of Tax Appeals, Volume 39U.S. Government Printing Office, 1939 - Taxation |
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Page lxxxi
... , who is a very close friend of the writer , Mr. Edward Fiedler , and who by the way is also a Governor of the Stock 162288m - 39- -6 Exchange , feels that the present Federal Administration is going ( 1 ) 3 HERMAN GOEDEL . 3.
... , who is a very close friend of the writer , Mr. Edward Fiedler , and who by the way is also a Governor of the Stock 162288m - 39- -6 Exchange , feels that the present Federal Administration is going ( 1 ) 3 HERMAN GOEDEL . 3.
Page 33
... present deficiencies . He asks for no increased deficiencies be- cause of error in that action . But if that was right , it would seem so , only , if the petitioning bank , as trustee of each of the two trusts , was carrying on business ...
... present deficiencies . He asks for no increased deficiencies be- cause of error in that action . But if that was right , it would seem so , only , if the petitioning bank , as trustee of each of the two trusts , was carrying on business ...
Page 34
... present case . All but one - third of that first part had been distributed to Frederick prior to his death . The remaining one - third was to be distributed to him at the age of 55 , but he died testate on March 21 , 1932 , just before ...
... present case . All but one - third of that first part had been distributed to Frederick prior to his death . The remaining one - third was to be distributed to him at the age of 55 , but he died testate on March 21 , 1932 , just before ...
Page 55
... present situation and reads as follows : ( a ) The last sentence of section 322 ( d ) of the Revenue Act of 1932 and of the Revenue Act of 1928 are amended to read as follows : " No such credit or refund shall be made of any portion of ...
... present situation and reads as follows : ( a ) The last sentence of section 322 ( d ) of the Revenue Act of 1932 and of the Revenue Act of 1928 are amended to read as follows : " No such credit or refund shall be made of any portion of ...
Page 82
... present case . There is a factual difference in that in Frank J. and Hubert Kelly Trust , the preferred stock was received as a dividend on common stock , which was the only class of stock theretofore authorized and outstanding , while ...
... present case . There is a factual difference in that in Frank J. and Hubert Kelly Trust , the preferred stock was received as a dividend on common stock , which was the only class of stock theretofore authorized and outstanding , while ...
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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.