Reports of the United States Tax Court, Volume 55The Court, 1970 - Taxation |
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Page viii
... Court's history to be asked to serve a third two - year term . " I would not want to leave the impression that John's every act on the Court came to a triumphant conclusion . As has been true on occa- sions in the lives of all trial ...
... Court's history to be asked to serve a third two - year term . " I would not want to leave the impression that John's every act on the Court came to a triumphant conclusion . As has been true on occa- sions in the lives of all trial ...
Page xiii
... Court's history . Judge Kern wore the mantle of greatness as a jurist , and he wore it with real humility . His services to the Court and to the public earned the biblical accolade : Well done , thou good and faithful servant . MR ...
... Court's history . Judge Kern wore the mantle of greatness as a jurist , and he wore it with real humility . His services to the Court and to the public earned the biblical accolade : Well done , thou good and faithful servant . MR ...
Page 5
United States. Tax Court. allowed by section 217 also appears to be deductible in computing tax- able income under section 63 ( a ) by virtue of section 211. This seeming inconsistency simply emphasizes to me that the characterization of ...
United States. Tax Court. allowed by section 217 also appears to be deductible in computing tax- able income under section 63 ( a ) by virtue of section 211. This seeming inconsistency simply emphasizes to me that the characterization of ...
Page 15
... Court , " In the interpretation of stat- utes , the function of the courts is easily stated . It is to construe the language so as to give effect to the intent of Congress . " United States v . Amer . Trucking Ass'ns . , 310 U.S. 534 ...
... Court , " In the interpretation of stat- utes , the function of the courts is easily stated . It is to construe the language so as to give effect to the intent of Congress . " United States v . Amer . Trucking Ass'ns . , 310 U.S. 534 ...
Page 38
... Court for the Western District of Tennessee on behalf of Martha . The complaint alleged two causes of action ... Court and in the U.S. Court of Appeals , final adjudication was favorable to the defendants and against Martha . As a result ...
... Court for the Western District of Tennessee on behalf of Martha . The complaint alleged two causes of action ... Court and in the U.S. Court of Appeals , final adjudication was favorable to the defendants and against Martha . As a result ...
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Common terms and phrases
agree allocation amount Ann Coates apply assets bad debt basis beneficiary certificates certiorari community property contract corporation cost decedent decedent's December 31 decision deduction director of internal distribution district director dividend earnings election employee expenditures expenses Federal income tax Fidelity filed follows funds gift gift tax gross income hardboard held Income Tax Regs income tax return incurred interest Internal Revenue Code issue lease liability Liberace liquidation loans loss Mason & Dixon ment notice of deficiency operating opinion ordinary income paid parent parties payments percent peti petition petitioner petitioner's Pintsch prior profit purchase purpose pursuant received regulations reserve respect Respondent determined RESPONDENT Docket respondent's Screen Gems section 162 shareholders shares statutory stipulated subsidiary supra taxable income taxpayer Teragram termination tion tioner trade or business transaction transferred trust instrument United voting trust York University
Popular passages
Page 214 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 594 - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses...
Page 52 - BASIS. (a) DEALERS IN PERSONAL PROPERTY. — Under regulations prescribed by the Commissioner with the approval of the Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the gross profit realized or to be realized when payment is completed, bears to the total contract price.
Page 502 - 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 148 - Generally, such relationship exists when the person for whom services are performed has the right to control and direct the individual who performs the services, not only as to the result to be accomplished by the work but also as to the details and means by which that result is accomplished ; that is, an employee is subject to the will and control of the employer not only as to what shall be done but how it shall be done.
Page 241 - ... the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Page 594 - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 447 - 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 35 - In the case of an Individual, there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year — (1) For the production or collection of Income; (2) For the management, conservation, or maintenance of property held for the production of Income; or (3) In connection with the determination, collection, or refund of any tax.
Page 648 - Commissioner and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.