Reports of the Tax Court of the United States, Volume 70U.S. Government Printing Office, 1978 - Taxation |
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Page 32
... loan or guarantee of a bank loan , or any combination of the foregoing or otherwise . *** ( d ) Tax Free Reorganization . The parties adopt this Plan intending that it shall constitute a tax - free reorganization under the provisions of ...
... loan or guarantee of a bank loan , or any combination of the foregoing or otherwise . *** ( d ) Tax Free Reorganization . The parties adopt this Plan intending that it shall constitute a tax - free reorganization under the provisions of ...
Page 73
... loan him the funds necessary to purchase the Trent River property ; in consideration for such loan , Mr. Mallard agreed to convey a life interest in the Trent River property to Mr. Scott . At the request of Mr. Scott , his nephew also ...
... loan him the funds necessary to purchase the Trent River property ; in consideration for such loan , Mr. Mallard agreed to convey a life interest in the Trent River property to Mr. Scott . At the request of Mr. Scott , his nephew also ...
Page 124
... loan in the amount of $ 45,000 from the Manufacturers & Traders Trust Co. of Buffalo , N. Y. ( hereinaf- ter the M. & T. Bank ) , the loan being secured by a mortgage on the 810 Abbott property . It was this liability that was assumed ...
... loan in the amount of $ 45,000 from the Manufacturers & Traders Trust Co. of Buffalo , N. Y. ( hereinaf- ter the M. & T. Bank ) , the loan being secured by a mortgage on the 810 Abbott property . It was this liability that was assumed ...
Page 125
... loan were used by Dr. D'Angelo as follows : $ 25,900 to complete building alterations to the 810 Abbott property ; $ 28,500 to retire installment loans of Dr. D'Angelo and his affiliates , including $ 9,000 to cover repayment of some ...
... loan were used by Dr. D'Angelo as follows : $ 25,900 to complete building alterations to the 810 Abbott property ; $ 28,500 to retire installment loans of Dr. D'Angelo and his affiliates , including $ 9,000 to cover repayment of some ...
Page 126
... loan to Dr. D'Angelo , was prohibited from making any payments of principal or interest ( including that previously accrued ) on its $ 111,727.85 in obligations to Dr. D'Angelo during the term of the SBA loan . This subordination of Dr ...
... loan to Dr. D'Angelo , was prohibited from making any payments of principal or interest ( including that previously accrued ) on its $ 111,727.85 in obligations to Dr. D'Angelo during the term of the SBA loan . This subordination of Dr ...
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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.