Reports of the Tax Court of the United States, Volume 6U.S. Government Printing Office, 1947 - Law reports, digests, etc Final issue of each volume includes table of cases reported in the volume. |
From inside the book
Results 1-5 of 100
Page 10
... Internal Revenue Code , and that amounts collected thereon were taxable in full , and not subject to limitations as capital gains ; held , further , that the petitioner had not recovered his entire base in the notes in a former year ...
... Internal Revenue Code , and that amounts collected thereon were taxable in full , and not subject to limitations as capital gains ; held , further , that the petitioner had not recovered his entire base in the notes in a former year ...
Page 17
... Internal Revenue Code , was $ 30,939.21 . Out of this amount the trustees paid the premium of $ 3,229.20 , leaving a balance of $ 27,710.01 which was distributed to petitioner as life beneficiary under article I , section 1 , of the ...
... Internal Revenue Code , was $ 30,939.21 . Out of this amount the trustees paid the premium of $ 3,229.20 , leaving a balance of $ 27,710.01 which was distributed to petitioner as life beneficiary under article I , section 1 , of the ...
Page 18
... tax- able year 1941 the trust had a net income , before applying section 162 ( b ) of the Internal Revenue Code , of $ 30,939.21 . The trustees used $ 3,229.20 of this income to pay the above mentioned premium and distributed the ...
... tax- able year 1941 the trust had a net income , before applying section 162 ( b ) of the Internal Revenue Code , of $ 30,939.21 . The trustees used $ 3,229.20 of this income to pay the above mentioned premium and distributed the ...
Page 19
... Internal Revenue Code and / or under Section 22 ( a ) of the Internal Revenue Code . " We shall consider first whether petitioner is taxable on all the trust income for the year 1941 under section 22 ( a ) . If we conclude that ...
... Internal Revenue Code and / or under Section 22 ( a ) of the Internal Revenue Code . " We shall consider first whether petitioner is taxable on all the trust income for the year 1941 under section 22 ( a ) . If we conclude that ...
Page 38
... tax $ 89,705 . 04 189 , 958. 42 $ 18,737 . 64 103 , 455. 92 $ 153 , 898.69 923 , 587.91 The contested issues are : ( 1 ) Whether petitioner is entitled to deduct in the taxable year 1940 , pursuant to section 23 of the Internal Revenue Code ...
... tax $ 89,705 . 04 189 , 958. 42 $ 18,737 . 64 103 , 455. 92 $ 153 , 898.69 923 , 587.91 The contested issues are : ( 1 ) Whether petitioner is entitled to deduct in the taxable year 1940 , pursuant to section 23 of the Internal Revenue Code ...
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Common terms and phrases
agreed agreement amended amount annuity assets assignment bank basis beneficiary benefit bonds capital stock cash certiorari Chertoff claims COMMISSIONER OF INTERNAL common stock computing contends contract corporation corpus cost Court death debentures decedent decedent's December 29 December 31 decision deduction deficiency determined disallowed distribution dividends Docket employees entitled excess profits tax expenses filed FINDINGS OF FACT follows fund gift gift tax gross income Haldeman held Helen Alexander Helvering Herschbach Howell income tax income tax return interest Internal Revenue Code investment issue January lease liability liquidation mortgage net income October 21 paid parties partnership payable payment percent peti petitioner petitioner's preferred stock premiums principal prior purchase purpose received respect respondent Revenue Act section 23 securities shares statute stipulated stockholders supra taxable taxpayer thereof thereto Thurlim tion tioner transfer trust estate trust instrument Turpentine wife
Popular passages
Page 236 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include — "(A) 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 489 - If an exchange would be within the provisions of subsection (b), (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 17 - Income which is to be distributed currently by the fiduciary to the beneficiaries, and income collected by a guardian of an infant which is to be held or distributed as the court may direct...
Page 783 - All the ordinary and necessary expenses paid or Incurred during the taxable year In carrying on any trade or business. Including a reasonable allowance for salaries or other compensation for personal services actually rendered...
Page 191 - ... (B) in a taxable year beginning after December 31, 1935, by a corporation in connection with a reorganization, 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.
Page 191 - 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 432 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 592 - 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 856 - The income of each shall be included in a single joint return in which case the tax shall be computed on the aggregate income and the liability with respect to the tax shall be joint and several.
Page 192 - reorganization" means (A) a statutory merger or consolidation, or (B) the acquisition by one corporation In exchange solely for all or a part of its voting stock: of at least 80 per centum of the voting stock and at least 80 per centum of the total number of shares of all other classes of stock of another corporation...