Reports of the Tax Court of the United States, Volume 70U.S. Government Printing Office, 1978 - Taxation |
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Page 31
... agreement , changed its name to Bercy Industries , Inc. ( hereinafter New Bercy or petitioner ) . Shareholders of ... agreement of merger provided : " Upon the effective date of merger ( the ' Merger Date ' ) the separate corporate ...
... agreement , changed its name to Bercy Industries , Inc. ( hereinafter New Bercy or petitioner ) . Shareholders of ... agreement of merger provided : " Upon the effective date of merger ( the ' Merger Date ' ) the separate corporate ...
Page 48
... agree with respondent . The dispute in this case concerns the section 179 ( d ) ( 2 ) ( A ) reference to prohibited relationships , a section which , in turn , refers to sections 267 ( b ) and ( c ) for a delineation of such ' Unless ...
... agree with respondent . The dispute in this case concerns the section 179 ( d ) ( 2 ) ( A ) reference to prohibited relationships , a section which , in turn , refers to sections 267 ( b ) and ( c ) for a delineation of such ' Unless ...
Page 75
... agreement contained the follow- ing convenant : 6. Covenant Not to Compete . In consideration of the Corporation redeeming the Two Hundred and Eighty - Four ( 284 ) shares owned by the Selling Shareholder , the Selling Shareholder and ...
... agreement contained the follow- ing convenant : 6. Covenant Not to Compete . In consideration of the Corporation redeeming the Two Hundred and Eighty - Four ( 284 ) shares owned by the Selling Shareholder , the Selling Shareholder and ...
Page 180
... agree with the Court of Claims that section 334 ( b ) ( 2 ) is not " elective " , but we do not agree with its conclusion that the broader Kimbell - Diamond doctrine therefore still should apply to those cases where the standards of ...
... agree with the Court of Claims that section 334 ( b ) ( 2 ) is not " elective " , but we do not agree with its conclusion that the broader Kimbell - Diamond doctrine therefore still should apply to those cases where the standards of ...
Page 193
... agreement on December 7 , 1964 , under which petitioner lent certain securities and cash to Command . The agreement provided that Command could use the securities and cash in its business and allowed Command to hypothecate the ...
... agreement on December 7 , 1964 , under which petitioner lent certain securities and cash to Command . The agreement provided that Command could use the securities and cash in its business and allowed Command to hypothecate the ...
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Common terms and phrases
9th Cir acquired affd agreement allocated amended amount annuity apply Arthur Smith assets Atlas Bank basis benefit capital carryback cash claimed COMMISSIONER OF INTERNAL community property contract Corp corporation Court decedent decedent's December December 31 decision distribution dividends divorce employee entitled estate tax exempt expenses facts fair market value Federal income tax fees filed franchise funds gross income Hayden Stone held Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service investment issue KBSI liability loan loss Malag marital deduction notice of deficiency operating organization paid parties partnership payable payments percent period petition petitioner petitioner's players prior proceeds purchase purposes pursuant qualified received regulations reorganization Rept respect Respondent determined RESPONDENT Docket respondent's Rule shareholders shares statutory stipulated supra taxable taxpayer transaction transfer trust trust instrument United Yawata
Popular passages
Page 584 - The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.
Page 377 - ... organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or...
Page 6 - For the production or collection of income; (2) For the management, conservation, or maintenance of property held for the production of income; or (3) ln connection with the determination, collection, or refund of any tax.
Page 202 - Compulsory Counterclaims. A pleading shall state as a counterclaim any claim which at the time of serving the pleading the pleader has against any opposing party, if it arises out of the transaction or occurrence that is the subject matter of the opposing party's claim...
Page 80 - While the question of dependency may involve principles of law, the fact remains that dependency is a question of fact to be determined from all the circumstances of the case and the burden of proving it rests upon him who claims it.
Page 143 - An individual who is legally separated from his spouse under a decree of divorce or of separate maintenance shall not be considered as married...
Page 175 - Is to be paid or may be paid over a period ending more than 10 years from the date of such decree...
Page 345 - An order striking out pleadings or parts thereof, or staying further proceedings until the order is obeyed, or dismissing the action or proceeding or any part thereof, or rendering a judgment by default against the disobedient party...
Page 617 - If, however, an intangible asset acquired through capital outlay is known from experience to be of value in the business or in the production of income for only a limited period, the length of which can be estimated from experience with reasonable certainty, such intangible asset may be the subject of a depreciation allowance, provided the facts are fully shown in the return or prior thereto to the satisfaction of the Commissioner.
Page 714 - ... Generally, services are considered rendered to the occupant if they are primarily for his convenience and are other than those usually or customarily rendered in connection with the rental of rooms or other space for occupancy only.