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 18
... effect of such a plan . There is no showing of any benefit directly or indirectly to pe- titioner such as the effect such payments might have upon the morale of , or as an incentive to , other officers or employees . Cf. American ...
... effect of such a plan . There is no showing of any benefit directly or indirectly to pe- titioner such as the effect such payments might have upon the morale of , or as an incentive to , other officers or employees . Cf. American ...
Page 21
... effect upon the morale or incentive of other officers or employees , and , there is no showing that the payments in question were in the nature of additional com- pensation for services previously rendered by petitioner's deceased ...
... effect upon the morale or incentive of other officers or employees , and , there is no showing that the payments in question were in the nature of additional com- pensation for services previously rendered by petitioner's deceased ...
Page 22
... effect on the morale and incentive of other executives . Monthly payments in the amounts authorized were made to the widow through 1948. Respondent allowed petitioner deductions for the amounts paid for the years 1938 through 1943 , and ...
... effect on the morale and incentive of other executives . Monthly payments in the amounts authorized were made to the widow through 1948. Respondent allowed petitioner deductions for the amounts paid for the years 1938 through 1943 , and ...
Page 28
... effect , as well as the economic effect , should be the same whether the several rights are represented by separate certificates or by a single certificate . It has been stated repeatedly that the incidence of taxation depends upon the ...
... effect , as well as the economic effect , should be the same whether the several rights are represented by separate certificates or by a single certificate . It has been stated repeatedly that the incidence of taxation depends upon the ...
Page 31
... effect of different types of premiums , and the necessity for apportion- ment , as shown by section 171 , formulates a sufficient basis upon which to require a limitation on the premiums allowed to be deducted under the regulation in ...
... effect of different types of premiums , and the necessity for apportion- ment , as shown by section 171 , formulates a sufficient basis upon which to require a limitation on the premiums allowed to be deducted under the regulation in ...
Other editions - View all
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.