Reports of the Tax Court of the United States, Volume 6U.S. Government Printing Office, 1947 - Law reports, digests, etc Final issue of each volume includes table of cases reported in the volume. |
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Common terms and phrases
abnormal income agreed agreement amount annuity assets bank basis beneficiary bonds capital stock cash certiorari Chertoff claims COMMISSIONER OF INTERNAL common stock computing contends contract corporation corpus cost Court debentures decedent December December 26 December 31 decision deduction deficiency determined disallowed distribution dividends Docket employees entitled excess profits tax expenses February 28 filed FINDINGS OF FACT follows fund gift tax gross income Haldeman Hanskat held Helvering hereinafter Herschbach income tax income tax returns interest Internal Revenue Code issue January lease liability liquidation ment mortgage net income October 31 old company paid par value parties partnership payable payment percent peti petitioner petitioner's preferred stock premiums principal prior purchase purpose received reserve respect respondent Revenue Act section 23 securities shares statute stipulated stockholders supra taxable taxpayer thereof tion tioner transfer trust estate trust instrument Turpentine wife
Popular passages
Page 61 - ... intended to take effect in possession or enjoyment at or after his death, 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 end before his death...
Page 778 - Gross income" Includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and Income derived...
Page 259 - ... (B) in a taxable year beginning after December 31, 1935, by a corporation in connection with a reorganization, 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 541 - Income collected by a guardian of an Infant which Is to be held or distributed as the court may direct; (3) Income received by estates of deceased persons during the period of administration or settlement of the estate; and (4) Income which, in the discretion of the fiduciary, may be either distributed to the beneficiaries or accumulated.
Page 385 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 203 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include 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 149 - December 31, 1917, by a corporation in connection with a reorganization, and immediately after the transfer an interest or control in such property of 50 per centum or more remained in the same persons or any of them, 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 149 - 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 149 - reorganization" means (A) a statutory merger or consolidation, or (B) the acquisition by one corporation In exchange solely for all or a part of its voting stock: of at least 80 per centum of the voting stock and at least 80 per centum of the total number of shares of all other classes of stock of another corporation...
Page 239 - In the case of oil and gas wells the allowance for depletion under section 23 (m) shall be 27 % per centum of the gross Income from the property during the taxable year, excluding from such gross income an amount equal to any rents or royalties paid or incurred by the taxpayer in respect of the property.