Reports of the United States Tax Court, Volume 80United States Tax Court, 1983 - Government publications |
From inside the book
Results 1-5 of 100
Page 31
... capital gain dividend " under sec . 852 ( b ) ( 3 ) ( C ) to shareholders of a regulated investment company ( a mutual fund ) cannot be treated as a dividend for purposes of increasing the sec . 163 ( d ) limitation . The case is ...
... capital gain dividend " under sec . 852 ( b ) ( 3 ) ( C ) to shareholders of a regulated investment company ( a mutual fund ) cannot be treated as a dividend for purposes of increasing the sec . 163 ( d ) limitation . The case is ...
Page 34
... capital gain over net short - term capital loss . Under the 1982 Act , an S corporation ( officially designated as such by the 1982 Act ) , is treated as a conduit much like a partnership . Items of income , deduction , or credit , and ...
... capital gain over net short - term capital loss . Under the 1982 Act , an S corporation ( officially designated as such by the 1982 Act ) , is treated as a conduit much like a partnership . Items of income , deduction , or credit , and ...
Page 39
... capital gain rather than ordinary income . A complicat- ed transaction , consisting of a series of incorporations , transfers , liquidations , and mergers , was then devised to disguise the terms of the agreement involving the 100 ...
... capital gain rather than ordinary income . A complicat- ed transaction , consisting of a series of incorporations , transfers , liquidations , and mergers , was then devised to disguise the terms of the agreement involving the 100 ...
Page 60
... capital- ization of interest will be described later in greater detail . Because of a scandal during the early 1960's involving the 14The financial powers described above were expressed in the act as follows : SEC . 87. The district may ...
... capital- ization of interest will be described later in greater detail . Because of a scandal during the early 1960's involving the 14The financial powers described above were expressed in the act as follows : SEC . 87. The district may ...
Page 93
... capital gains . You would form other corporations which would take title to the land involved , the stock would be sold to other subsidiaries of Howard Corporation , a new corporation would issue a note for $ 500,000.00 , which you ...
... capital gains . You would form other corporations which would take title to the land involved , the stock would be sold to other subsidiaries of Howard Corporation , a new corporation would issue a note for $ 500,000.00 , which you ...
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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.