 ... 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...  Reports of the Tax Court of the United States - Page 5by United States. Tax Court - 1962Full view - About this book
 | United States. Court of Claims, Audrey Bernhardt - Law reports, digests, etc - 1954 - 1160 pages
...(1) any person or persons acquire, on or after October 8, 1940, directly or Indirectly, control of a corporation, * • * and the principal purpose for...was made Is evasion or avoidance of Federal Income or excess profits tax by securing the benefit of a deduction, credit, or other allowance which such... | |
 | Administrative law - 1939 - 1522 pages
...of the acquiring corporation, is determined by reference to the basis in the hands of tbe transferor corporation, and the principal purpose for which such...was made is evasion or avoidance of Federal income or excess profits tax "by securing the benefit of a deduction, credit, or other allowance which such... | |
 | United States - Law - 1988 - 1290 pages
...than 2 years after the acquisition date, and (D) the principal purpose for such liquidation is the evasion or avoidance of Federal income tax by securing...benefit of a deduction, credit, or other allowance which the acquiring corporation would not otherwise enjoy, then the Secretary may disallow such deduction,... | |
 | United States - Law - 1953 - 1744 pages
...of the acquiring corporation, is determined by reference to the basis in the hands of the transferor corporation, and the principal purpose for which such...was made is evasion or avoidance of Federal income or excess profits tax by securing the benefit of a deduction, credit, or other allowance which such... | |
 | United States - Law - 1965 - 1110 pages
...acquiring corporation, Is determined tv reference to the basis in the hands of the transferor ccrporation, and the principal purpose for which such acquisition was made is evasion or avoidance of Federal {268 Page 5055 5270 income tax by securing the benefit of a deduction, credit, or other allowance which... | |
 | United States - 1944 - 1344 pages
...of the acquiring corporation, is determined by reference to the basis in the hands of the transferor corporation, and the principal purpose for which such...was made is evasion or avoidance of Federal income or excess profits tax by securing the benefit of a deduction, credit, or other allowance which such... | |
 | United States. Congress. Senate. Committee on Finance - Finance, Public - 1944 - 1196 pages
...which such acquisition was made or availed of is the avoidance of Federal income or excess-profits tax by securing the benefit of a deduction, credit, or other allowance, then such deduction, credit, or other allowance shall not be allowed. What is wrong with that in principle?... | |
 | United States. Congress. Senate. Committee on Finance - Finance - 1944 - 1198 pages
...which such acquisition was made or availed of is the avoidance of Federal income or excess profits tax by securing the benefit of a deduction, credit, or other allowance, then such deduction, credit, or other allowance shall not be allowed." The Commissioner is further... | |
 | United States. Congress. Senate. Committee on Finance - Finance - 1944 - 1194 pages
...which such acquisition was made or availed of is the avoidance of Federal income or excess-profits tax by securing the benefit of a deduction, credit, or other allowance. It is assumed that this provision is directed primarily at the practice of acquiring corporations with... | |
| |
