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. |
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Results 1-5 of 100
Page 5
... opinion the respondent's views should be sustained . Since the opinion of the Supreme Court of the United States in the Vir- ginian Hotel case , depreciation must be computed by taking into con- sideration any claims for depreciation ...
... opinion the respondent's views should be sustained . Since the opinion of the Supreme Court of the United States in the Vir- ginian Hotel case , depreciation must be computed by taking into con- sideration any claims for depreciation ...
Page 12
... opinion the peti- tioners ' views may not be sustained , for there is no contention that the notes carried interest coupons and nothing in the record indicates that they were in registered form , within the meaning of the statutory ...
... opinion the peti- tioners ' views may not be sustained , for there is no contention that the notes carried interest coupons and nothing in the record indicates that they were in registered form , within the meaning of the statutory ...
Page 28
... opinion that the sales were completed sales , giving rise to a debt . We are also of the opinion that the debt became worthless during the tax year . The institution of litigation where such action is not justified by any hope of ...
... opinion that the sales were completed sales , giving rise to a debt . We are also of the opinion that the debt became worthless during the tax year . The institution of litigation where such action is not justified by any hope of ...
Page 58
... opinion there is no more reason for the respondent to question the deduction of the amounts paid in the taxable years before us than in prior years . The respondent does not contend that the amount of the premium paid in 1940 , together ...
... opinion there is no more reason for the respondent to question the deduction of the amounts paid in the taxable years before us than in prior years . The respondent does not contend that the amount of the premium paid in 1940 , together ...
Page 59
... opinion that the evidence does not disprove his determination . I therefore concur in the opinion so far as it dis- allows the deduction from gross income of 1941 of the $ 1,000,000 in question . BLACK , J. , dissenting : I wish to note ...
... opinion that the evidence does not disprove his determination . I therefore concur in the opinion so far as it dis- allows the deduction from gross income of 1941 of the $ 1,000,000 in question . BLACK , J. , dissenting : I wish to note ...
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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 computed contends contract corporation corpus cost Court death debentures decedent decedent's December 29 December 31 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 lease liability liquidation ment 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 787 - 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 860 - 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...