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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Page 14
... rules and regulations . " The burden of proof on this issue is upon petitioners . Marcello v . Commissioner , 380 F.2d ... Rule 50 . GEORGE A. ROESEL AND PATRICIA M. ROESEL , PETITIONER V. COMMIS- SIONER OF INTERNAL REVENUE , RESPONDENT ...
... rules and regulations . " The burden of proof on this issue is upon petitioners . Marcello v . Commissioner , 380 F.2d ... Rule 50 . GEORGE A. ROESEL AND PATRICIA M. ROESEL , PETITIONER V. COMMIS- SIONER OF INTERNAL REVENUE , RESPONDENT ...
Page 22
... RULE . - The undistributed taxable income of an electing small business corporation for any taxable year shall be included in the gross income of the shareholders of such corporation in the manner and to the extent set forth in this ...
... RULE . - The undistributed taxable income of an electing small business corporation for any taxable year shall be included in the gross income of the shareholders of such corporation in the manner and to the extent set forth in this ...
Page 23
... RULES APPLICABLE TO EARNINGS AND PROFITS OF ELECT- ING SMALL BUSINESS CORPORATIONS . ( a ) REDUCTION FOR UNDISTRIBUTED TAXABLE INCOME . - The accumulated earnings and profits of an electing small business corporation as of the close of ...
... RULES APPLICABLE TO EARNINGS AND PROFITS OF ELECT- ING SMALL BUSINESS CORPORATIONS . ( a ) REDUCTION FOR UNDISTRIBUTED TAXABLE INCOME . - The accumulated earnings and profits of an electing small business corporation as of the close of ...
Page 31
... rule under section 162 ( a ) ( 2 ) , saying travel " away from home " is that which requires " sleep or rest . " 389 U.S. at 446. Although Correll involved deductions for meals and lodg- ing , the overnight rule applies to all " travel ...
... rule under section 162 ( a ) ( 2 ) , saying travel " away from home " is that which requires " sleep or rest . " 389 U.S. at 446. Although Correll involved deductions for meals and lodg- ing , the overnight rule applies to all " travel ...
Page 43
... rules which are to aid doubtful meaning need no discussion . Caldwell v . United States , 114 F.2d 995 ( C.A. 3 ... rule that a power of appointment created by will is created on the date of the testator's death . Second , assuming ...
... rules which are to aid doubtful meaning need no discussion . Caldwell v . United States , 114 F.2d 995 ( C.A. 3 ... rule that a power of appointment created by will is created on the date of the testator's death . Second , assuming ...
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Common terms and phrases
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...