Reports of the United States Tax Court, Volume 80United States Tax Court, 1983 - Government publications |
From inside the book
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Page 84
United States. Tax Court. partnership on its exchange of 500 shares of Foster California Corporation stock for 196.38 acres of land received from that corporation , will also be disregarded , such exchange being part of the " Westway ...
United States. Tax Court. partnership on its exchange of 500 shares of Foster California Corporation stock for 196.38 acres of land received from that corporation , will also be disregarded , such exchange being part of the " Westway ...
Page 87
... exchange for 100 percent of that corporation's stock , which was titled in the name of the partnership . This exchange was treated as a nontaxable transaction . Foster Bayou had been formed by the partnership on or slightly before that ...
... exchange for 100 percent of that corporation's stock , which was titled in the name of the partnership . This exchange was treated as a nontaxable transaction . Foster Bayou had been formed by the partnership on or slightly before that ...
Page 88
... exchange for 500 shares , or one - half , of that corporation's authorized stock.26 This exchange was treated as a nontaxable transaction . Foster California had been formed by the partnership on January 17 , 1961 , but had been dormant ...
... exchange for 500 shares , or one - half , of that corporation's authorized stock.26 This exchange was treated as a nontaxable transaction . Foster California had been formed by the partnership on January 17 , 1961 , but had been dormant ...
Page 90
... exchange for its stock , Foster California transferred to the partnership on August 4 , 1964 , the 196.638 acres of land in Neighborhoods Two and Three which it had acquired from the partnership on December 3 , 1963. This transaction ...
... exchange for its stock , Foster California transferred to the partnership on August 4 , 1964 , the 196.638 acres of land in Neighborhoods Two and Three which it had acquired from the partnership on December 3 , 1963. This transaction ...
Page 145
... exchange for its stock or securities if immediately after the exchange the transferor controls the corporation . Similarly , under section 1032,63 a corporation does not recognize gain or loss when property is transferred to it in exchange ...
... exchange for its stock or securities if immediately after the exchange the transferor controls the corporation . Similarly , under section 1032,63 a corporation does not recognize gain or loss when property is transferred to it in exchange ...
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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.