Reports of the United States Tax Court, Volume 56United States Tax Court, 1971 - Government publications Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
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Results 1-5 of 100
Page 1
... deficien- cies and addition to tax in the petitioners ' income tax : 1963__ 1964_ Year Deficiency Addition to tax sec . 6653 ( a ) . I.R.C. 1954 $ 4 , 150. 77 8 , 299. 09 $ 207 . 54 1 Four issues remain for decision : 1 ( 1 )
... deficien- cies and addition to tax in the petitioners ' income tax : 1963__ 1964_ Year Deficiency Addition to tax sec . 6653 ( a ) . I.R.C. 1954 $ 4 , 150. 77 8 , 299. 09 $ 207 . 54 1 Four issues remain for decision : 1 ( 1 )
Page 27
... Decisions will be entered under Rule 50 . WILLIAM B. TURNER , PETITIONER V. COMMISSIONER OF INTERNAL REVENUE ... decision are ( 1 ) whether the petitioner , a temporary corporate employee , is entitled to deduct automobile ex ...
... Decisions will be entered under Rule 50 . WILLIAM B. TURNER , PETITIONER V. COMMISSIONER OF INTERNAL REVENUE ... decision are ( 1 ) whether the petitioner , a temporary corporate employee , is entitled to deduct automobile ex ...
Page 30
... decision of the U.S. Supreme Court in United States v . Correll , 389 U.S. 299 ( 1967 ) , courts generally had paid scant attention to the distinction between travel expenses deductible under section 162 ( a ) ( 2 ) and transportation ...
... decision of the U.S. Supreme Court in United States v . Correll , 389 U.S. 299 ( 1967 ) , courts generally had paid scant attention to the distinction between travel expenses deductible under section 162 ( a ) ( 2 ) and transportation ...
Page 31
... 24 ( C.A. 5 , 1964 ) . Finally , the cases holding that 1 - day trips constitute " travel away from home " were nullified by the Correll decision . Turning now to petitioner's arguments , we note that since ( 27 ) 31 WILLIAM B. TURNER.
... 24 ( C.A. 5 , 1964 ) . Finally , the cases holding that 1 - day trips constitute " travel away from home " were nullified by the Correll decision . Turning now to petitioner's arguments , we note that since ( 27 ) 31 WILLIAM B. TURNER.
Page 33
... decision in Sanders v . Commissioner , 439 F.2d 296 ( C.A. 9 , 1971 ) . The petitioner received $ 330 as a travel allowance in 1966. He did not report this sum as gross income . There is no indication that this sum was to reimburse the ...
... decision in Sanders v . Commissioner , 439 F.2d 296 ( C.A. 9 , 1971 ) . The petitioner received $ 330 as a travel allowance in 1966. He did not report this sum as gross income . There is no indication that this sum was to reimburse the ...
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affiliation agreement alimony allocable amount annuity assets bank basis Brigham Young University cash certificates certiorari claimed collateral estoppel Commissioner computed contract corporation Court Dave Beck decedent December December 31 deduction deficiency deposit Dillin disallowed distribution Edgar entitled escrow evidence exempt expenditures expenses fair market value February 28 Federal income tax filed follows funds Garth's gross income Harold held hereinafter included Income Tax Regs income tax returns interest Internal Revenue Code issue joint liability loans loss ment mortgage operation ordinary income paid parties payable payments percent period peti petitioner petitioner's prior purchase purposes Pyrometric Cones received record referred remainderman residence respect Respondent determined respondent's Riss shareholders shares sold station stipulated Strain Trust supra taxable income taxicab taxpayer tion tioner trade or business transaction transferred trust instrument union United wife WNCT-TV
Popular passages
Page 124 - ... it is no longer equitable that the judgment should have prospective application; or (6) any other reason justifying relief from the operation of the judgment.
Page 177 - ... (1) 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 735 - The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.
Page 119 - An individual shall be considered as owning the stock owned, directly or Indirectly, by or for his family...
Page 567 - 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 193 - ... 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 654 - Is divorced or legally separated from her husband under a decree of divorce or of separate maintenance...
Page 276 - A casual sale or other casual disposition of personal property (other than 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) for a price exceeding $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a).
Page 177 - ... or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact and before his death (1) the possession or enjoyment of, or the right to the income from, the property...
Page 408 - In computing net income there shall be allowed as deductions : ******* (e) LOSSES BY INDIVIDUALS. — In the case of an individual, losses sustained during the taxable year and not compensated for by insurance or otherwise — (1) if incurred in trade or business ; or (2) If incurred in any transaction entered into for profit, though not connected with the trade or business...