Reports of the United States Tax Court, Volume 80United States Tax Court, 1983 - Government publications |
From inside the book
Results 1-5 of 88
Page 432
... decedent's estate , all title and right of possession in the decedent's personalty shall be vested in the personal represen- tative for the purpose of administering the decedent's estate . N.C. Gen. Stat . sec . 28A - 15-11 ( 1976 ) ...
... decedent's estate , all title and right of possession in the decedent's personalty shall be vested in the personal represen- tative for the purpose of administering the decedent's estate . N.C. Gen. Stat . sec . 28A - 15-11 ( 1976 ) ...
Page 433
... decedent . Merger , therefore , could occur only when the notes were distributed to Margarette in her individual capacity as legatee , and not while she held them as personal representa- tive . And as we shall discuss , we reject ...
... decedent . Merger , therefore , could occur only when the notes were distributed to Margarette in her individual capacity as legatee , and not while she held them as personal representa- tive . And as we shall discuss , we reject ...
Page 478
... Decedent's wife made a gift between Sept. 8 , 1976 , and Jan. 1 , 1977 , which was considered as made one - half by the decedent pursuant to an election under sec . 2513 , I.R.C. 1954. Decedent used $ 18,389.38 of his specific exemption ...
... Decedent's wife made a gift between Sept. 8 , 1976 , and Jan. 1 , 1977 , which was considered as made one - half by the decedent pursuant to an election under sec . 2513 , I.R.C. 1954. Decedent used $ 18,389.38 of his specific exemption ...
Page 479
... decedent and his wife each consented to consider those gifts as made one - half by the decedent and one - half by his wife , pursuant to section 2513. In computing the amount of taxable gifts on his gift tax return , decedent deducted ...
... decedent and his wife each consented to consider those gifts as made one - half by the decedent and one - half by his wife , pursuant to section 2513. In computing the amount of taxable gifts on his gift tax return , decedent deducted ...
Page 480
... decedent against the tax imposed by section 2001 . ( b ) PHASE - IN Of $ 47,000 CREDIT.— In the case of decedents dying in : 1977 Subsection ( a ) shall be applied by substituting for ' $ 47,000 ' the following amount : $ 30,000 ( c ) ...
... decedent against the tax imposed by section 2001 . ( b ) PHASE - IN Of $ 47,000 CREDIT.— In the case of decedents dying in : 1977 Subsection ( a ) shall be applied by substituting for ' $ 47,000 ' the following amount : $ 30,000 ( c ) ...
Other editions - View all
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.