Reports of the Tax Court of the United States, Volume 37U.S. Government Printing Office, 1962 - 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 4
... Internal Revenue Code ( 1954 ) . " The two issues are thus stated in petitioner's opening brief : a . Was the principal purpose of the acquisition of the corporation by its sole stockholder that of tax avoidance so as to bar the ...
... Internal Revenue Code ( 1954 ) . " The two issues are thus stated in petitioner's opening brief : a . Was the principal purpose of the acquisition of the corporation by its sole stockholder that of tax avoidance so as to bar the ...
Page 10
... Internal Revenue Code . " In its original petition , petitioner alleged that the entire $ 5,100 is deductible under section 162 ( a ) . By amended petition , it alleged the $ 5,100 is an allowable deduction for 1954 under the provisions ...
... Internal Revenue Code . " In its original petition , petitioner alleged that the entire $ 5,100 is deductible under section 162 ( a ) . By amended petition , it alleged the $ 5,100 is an allowable deduction for 1954 under the provisions ...
Page 12
... Internal Revenue Code of 1954 and section 1.404 ( a ) -12 , Income Tax Regs . , promulgated thereunder . Petitioner argues that the reference which is made to section 162 in section 404 ( a ) and section 1.404 ( a ) –12 relates only to ...
... Internal Revenue Code of 1954 and section 1.404 ( a ) -12 , Income Tax Regs . , promulgated thereunder . Petitioner argues that the reference which is made to section 162 in section 404 ( a ) and section 1.404 ( a ) –12 relates only to ...
Page 14
... Internal Revenue Code , Sec . 115 , 26 U.S.C.A. 115 , ' Distributions by corporations ' : " The term " dividend " when used in this chapter means any distribution made by a corporation to its shareholders , whether in money or in other ...
... Internal Revenue Code , Sec . 115 , 26 U.S.C.A. 115 , ' Distributions by corporations ' : " The term " dividend " when used in this chapter means any distribution made by a corporation to its shareholders , whether in money or in other ...
Page 15
... Internal Revenue Code . " In its original petition filed herein , petitioner alleged that the entire $ 5,100 is deductible under section 162 ( a ) . By amended peti- tion , it alleged the $ 5,100 is an allowable deduction for 1954 under ...
... Internal Revenue Code . " In its original petition filed herein , petitioner alleged that the entire $ 5,100 is deductible under section 162 ( a ) . By amended peti- tion , it alleged the $ 5,100 is an allowable deduction for 1954 under ...
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Common terms and phrases
accrual agreement amount applicable assets bank base period basis business expenses calcium carbonates capital gain cash certiorari City Savings claimed Clay Brown coal Commissioner Company computed conduit contract corporation cost Court debentures debt December December 31 deduction deficiency director of internal disallowed Docket duct electric employees excess profits tax expenditures Falstaff beer filed follows French Morocco gift tax gross income held hereinafter income tax return incurred installed interest Internal Revenue Code involved issue January Laneco lease liability loan loss March 11 McGraw Melvin ment Missisquoi notes operating ordinary and necessary ordinary income paid parties partnership payments percent peti petitioner petitioner's premium prior production purchase purpose receipt received regulations Reiner's residence respect Respondent determined respondent's shares sold stipulated stockholders supra taxpayer thereof tion tioner trade or business transaction trust United
Popular passages
Page 863 - 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; but In the case of an exchange by two or more persons this paragraph shall apply only If the amount of the stock and securities received by each is substantially In proportion to his Interest in the property prior to the exchange.
Page 863 - ... (6) TAX-FREE EXCHANGES GENERALLY. — If the property was acquired, after February 28, 1913, upon an exchange described in section 112 (b) to (e), inclusive, the basis shall be the same as in the case of the property exchanged, decreased in the amount of any money received by the taxpayer and increased in the amount of gain or decreased in the amount of loss to the taxpayer that was recognized upon such exchange under the law applicable to the year in which the exchange was made.
Page 94 - 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 66 - Between members of a family, as defined in paragraph (2) (D); (B) Except in the case of distributions in liquidation, between an individual and a corporation more than 50 per centum in value of the outstanding stock of which is owned, directly or indirectly, by or for such individual...
Page 863 - In addition to such stock or securities), or (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.
Page 818 - For the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body...
Page 5 - ... the principal purpose for which such acquisition was made is evasion or avoidance of Federal income tax by securing the benefit of a deduction, credit, or other allowance which such person or corporation would not otherwise enjoy, then the Secretary may disallow such deduction, credit, or other allowance.
Page 661 - ... attributable to property transferred (in trust or otherwise) in discharge of, a legal obligation which, because of the marital or family relationship, is imposed upon or incurred by such husband under such decree or under a written instrument incident to such divorce or separation...
Page 64 - An Individual shall be considered as owning the stock owned, directly or Indirectly, by or for his family...
Page 121 - 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.