Reports of the Tax Court of the United States, Volume 38U.S. Government Printing Office, 1963 - Law reports, digests, etc Final issue of each volume includes table of cases reported in the volume. |
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Results 1-5 of 74
Page 12
... intention of Congress in enacting section 1239 to permit the result petitioners now seek . Section 1239 had its counterpart in section 328 of the Revenue Act of 1951 which added subsection ( o ) to section 117 of the 1939 Code . The ...
... intention of Congress in enacting section 1239 to permit the result petitioners now seek . Section 1239 had its counterpart in section 328 of the Revenue Act of 1951 which added subsection ( o ) to section 117 of the 1939 Code . The ...
Page 13
... intention ; and " that intention is to be ascertained , not by taking the word or clause in question from its setting and viewing it apart , but by con- sidering it in connection with the context , the general purposes of the statute in ...
... intention ; and " that intention is to be ascertained , not by taking the word or clause in question from its setting and viewing it apart , but by con- sidering it in connection with the context , the general purposes of the statute in ...
Page 79
... intention to transfer any While we know that Kathryn's permanent residence was in California from 1949 until her death , we have no other evidence suggesting that all of the funds Kathryn withdrew from the joint account were withdrawn ...
... intention to transfer any While we know that Kathryn's permanent residence was in California from 1949 until her death , we have no other evidence suggesting that all of the funds Kathryn withdrew from the joint account were withdrawn ...
Page 80
... intentions ( see People v . Stanford , 16 Cal . 2d . 247 , 105 P. 2d . 969 , 970 ( 1940 ) , where the court stressed the fact that the defendant " knew that Mrs. Stevens was unaccustomed to business dealings , had implicit confidence in ...
... intentions ( see People v . Stanford , 16 Cal . 2d . 247 , 105 P. 2d . 969 , 970 ( 1940 ) , where the court stressed the fact that the defendant " knew that Mrs. Stevens was unaccustomed to business dealings , had implicit confidence in ...
Page 81
... intention of granting the defendants an in such definition . It is true that where , as in the cases of People v . Royce , 106 Cal . 173 , 37 P. 630 , 39 P. 524 , and People v . Page , 116 Cal . 386 , 48 P. 326 , the money is deposited ...
... intention of granting the defendants an in such definition . It is true that where , as in the cases of People v . Royce , 106 Cal . 173 , 37 P. 630 , 39 P. 524 , and People v . Page , 116 Cal . 386 , 48 P. 326 , the money is deposited ...
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Common terms and phrases
acquired addition adjustments agreed agreement allowed amended apply assets basis capital gain cash certiorari City of Gunnison claimed collateral estoppel computed contract corporation cost Court death decedent decedent's December 31 decision deduction depreciation director of internal distribution district director dividend Docket earnings employees entitled equipment escrow expenses fair market value filed fiscal follows gift Grand Bahama gross income held hereinafter included income tax return interest Internal Revenue Code issue January Jerseymaid June June 30 Knights of Columbus lease Lexington Herald-Leader liability liquidation ment mortgage October 31 ordinary income paid parties partner partnership payable payments percent period peti petitioner petitioner's Pomona College principal prior profits purchase purpose pursuant real estate respect Respondent determined respondent's September 30 settlor shareholders shares sold Speedway statute stipulated stockholders Stoll supra taxable income taxpayer Thorson tion tioner transfer Trust Company United wife
Popular passages
Page 9 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.
Page 234 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...
Page 472 - Traveling expenses (including the entire amount expended for meals and lodging) while away from home In the pursuit of a trade or business...
Page 88 - If the taxpayer omits from gross Income an amount properly Includible therein -which Is In excess of 26 percent of the amount of gross Income stated In the return, the tax may be assessed, or a proceeding In court for the collection of such tax may be begun without assessment, at any time within 6 years after the return was filed. For purposes of this subparagraph — (I) In the case of a trade or business, the term "gross Income...
Page 699 - In the case of a false or fraudulent return with intent to evade tax or of a failure to file a return the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time.
Page 9 - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 699 - If any part of any deficiency is due to negligence, or intentional disregard of rules and regulations but without intent to defraud. 5 per centum of the total amount of the deficiency (In addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency, except that the provisions of section 571, relating to interest on deficiencies, shall not be applicable.
Page 327 - Do any other act which would make it impossible to carry on the ordinary business of the partnership, (d) Confess a judgment, (e) Submit a partnership claim or liability to arbitration or reference.
Page 16 - If an intangible asset is known from experience or other factors to be of use in the business or in the production of income for only a limited period, the length of which can be estimated with reasonable accuracy, such an intangible asset may be the subject of a depreciation allowance.
Page 191 - Includes periodic payments (whether or not made at regular intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, In discharge of) a legal obligation which, because of the marital or family relationship, is Imposed on or Incurred by the husband under the decree or under a written instrument incident to such divorce or separation.