Reports of the United States Tax Court, Volume 80United States Tax Court, 1983 - Government publications |
From inside the book
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Page 16
... basis in the property distributed to it is equal to the adjusted basis of the stock of the subsidiary with respect to which the distribution was made . Thus , in the case of a purchase of all the stock of a subsidiary followed by a ...
... basis in the property distributed to it is equal to the adjusted basis of the stock of the subsidiary with respect to which the distribution was made . Thus , in the case of a purchase of all the stock of a subsidiary followed by a ...
Page 17
... basis rule that property obtained from the seller receives a basis equal to the consideration given by the buyer ( sec . 1.1012- ( a ) , Income Tax Regs . ) is suspended , or at least extended into a new realm . Here , according to ...
... basis rule that property obtained from the seller receives a basis equal to the consideration given by the buyer ( sec . 1.1012- ( a ) , Income Tax Regs . ) is suspended , or at least extended into a new realm . Here , according to ...
Page 22
... basis of the property . Rather , this premium gives birth to a quantity of free - floating basis which attaches to an alleged intangible asset which is none other than the incarnation of the expected surplus benefit that motivated the ...
... basis of the property . Rather , this premium gives birth to a quantity of free - floating basis which attaches to an alleged intangible asset which is none other than the incarnation of the expected surplus benefit that motivated the ...
Page 23
... basis of property is equal to the amount of cash paid for such property . Petitioner's proposition would demolish this faithful truism , opening the door to a vast new arena of controversy . We refuse to open this door . The fallacy ...
... basis of property is equal to the amount of cash paid for such property . Petitioner's proposition would demolish this faithful truism , opening the door to a vast new arena of controversy . We refuse to open this door . The fallacy ...
Page 39
... basis in Neighbor- hoods Two and Three by an amount equal to approximately twice that which FP had become obligated to pay to the bank as a bonus . Held : a . Respondent's categorization of the Westway notes as inter- est is an issue ...
... basis in Neighbor- hoods Two and Three by an amount equal to approximately twice that which FP had become obligated to pay to the bank as a bonus . Held : a . Respondent's categorization of the Westway notes as inter- est is an issue ...
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Common terms and phrases
9th Cir acquired adjustment affd agreement allocation Alps Corp amount application assets basis benefit bonding bonus Brewer's Island capital carryback cash claimed Commissioner contract corporation Court debt decedent deduction depreciation disallowed distribution district docket earnings escrow Estero exchange exemption expenses fact fair market value Federal income tax filed fiscal Foster City Foster partnership gift tax GRFF gross income held Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service investment issue Jack Foster Kroger land lease Levon Records liability loan master recordings Neighborhood nonrecourse notice of deficiency operating loss paid parties partners payments percent petitioner petitioner's prior profits purposes pursuant qualified real property received reinsurance rent rental Rept respondent's rule section 482 shareholders shares specific supra T.C. Memo taxable income taxpayer tion trade or business transaction transfer trust U.S. dollar United Westway
Popular passages
Page 1159 - ... 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 1118 - Relevant evidence" means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.
Page 1159 - ... 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 690 - Imposed by section 531 shall apply to every corporation (other than those described in subsection (b) ) formed or availed of for the purpose of avoiding the income tax with respect to Its shareholders or the shareholders of any other corporation, by permitting earnings and profits to accumulate Instead of being divided or distributed.
Page 142 - ... in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 503 - 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 141 - The legal right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid them, by means which the law permits, cannot be doubted.
Page 188 - In contravention of the agreement between the partners, where the circumstances do not permit a dissolution under any other provision of this section, by the express will of any partner at any time...
Page 849 - In determining his income tax. each partner shall take into account separately his distributive share of the partnership's...
Page 365 - If such trade or business does not consist of the performance of services by the taxpayer as an employee.