Reports of the Tax Court of the United States, Volume 23U.S. Government Printing Office, 1956 - Law reports, digests, etc |
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Page 12
... average base period net income . Held , that petitioner is not entitled to relief as claimed , since it has failed to establish or show a constructive average base period net income which would result in a greater excess profits credit ...
... average base period net income . Held , that petitioner is not entitled to relief as claimed , since it has failed to establish or show a constructive average base period net income which would result in a greater excess profits credit ...
Page 13
... average base period net income , for excess profits tax purposes . FINDINGS OF FACT . The petitioner , an Ohio corporation , was incorporated July 28 , 1937 , with its principal office in Middletown , Ohio . It was formed for the ...
... average base period net income , for excess profits tax purposes . FINDINGS OF FACT . The petitioner , an Ohio corporation , was incorporated July 28 , 1937 , with its principal office in Middletown , Ohio . It was formed for the ...
Page 16
... average base period net income under section 722 as claimed by petitioner in its applications for section 722 relief was $ 30,930 . It was the determination of the respondent , for each of the said years , that petitioner had not ...
... average base period net income under section 722 as claimed by petitioner in its applications for section 722 relief was $ 30,930 . It was the determination of the respondent , for each of the said years , that petitioner had not ...
Page 17
... average base period net income , in lieu of the average base period net income otherwise determined . under the statute . In section 722 ( b ) ( 4 ) of the 1939 Code , it is provided that the tax " shall be considered to be excessive ...
... average base period net income , in lieu of the average base period net income otherwise determined . under the statute . In section 722 ( b ) ( 4 ) of the 1939 Code , it is provided that the tax " shall be considered to be excessive ...
Page 18
... average base period net income is an inadequate standard of normal earnings , but must establish what would be a fair and just amount representing normal earnings , and there is still no relief under section 722 unless the excess ...
... average base period net income is an inadequate standard of normal earnings , but must establish what would be a fair and just amount representing normal earnings , and there is still no relief under section 722 unless the excess ...
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Common terms and phrases
agreement alimony amount assets average base period basis capital gain cash cent certiorari claimed collector of internal COMMISSIONER OF INTERNAL computing contract corporation cost Court Cury's Dahar Cury decedent decedent's December decree deduction deficiency distribution dividend Docket earnings estate tax excess profits tax expenses fair market value farm Feagans Federal Housing Administration filed FINDINGS OF FACT fiscal year ended follows Ford Motor Company Greenspon gross income held included income tax income tax return interest Internal Revenue Code inventory issue January January 31 lease liability loss McBride ment Morgoil mortgage October operation option ordinary income paid partnership payment period net income peti petitioner petitioner's policies prior purchase purposes pursuant received record rental respondent determined respondent's Rule 50 section 117 section 23 shares sold stipulated stockholders supra taxable taxpayer tion tioner trade or business transferred trust wife
Popular passages
Page 536 - The net income shall be computed upon the basis of the taxpayer's annual accounting period (fiscal year or calendar year, as the case may be) in accordance with the method of accounting regularly employed in keeping the books of such taxpayer ; but if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income...
Page 142 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Page 413 - If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend...
Page 575 - In the case of mines, oil and gas wells, other natural deposits, and timber, a reasonable allowance for depletion and for depreciation of Improvements, accordIng to the peculiar conditions in each case...
Page 148 - BASIS. (a) DEALERS IN PERSONAL PROPERTY. — Under regulations prescribed by the Commissioner with the approval of the Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the gross profit realized or to be realized when payment is completed, bears to the total contract price.
Page 576 - Includes not merely the extraction of the ores or minerals from the ground but also the ordinary treatment processes normally applied by mine owners or operators In order to obtain the commercially marketable mineral product or products...
Page 671 - Capital losses. Losses from sales or exchanges of capital assets shall be allowed only to the extent allowed in sections 1211 and 1212.
Page 191 - ... even if such taxpayer is deceased, or is under a legal disability, or. in the case of a corporation, has terminated its existence.
Page 527 - ... also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived from any source whatever.
Page 415 - ... (B) as paid-in surplus or as a contribution to capital, then the basis shall be the same as It would be In the hands of the transferor. Increased In the amount of gain or decreased In the amount of loss recognized to the transferor upon such transfer under the law applicable to the year In which the transfer was made.