Reports of the Tax Court of the United States, Volume 70U.S. Government Printing Office, 1978 - Taxation |
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Results 1-5 of 100
Page 20
... pursuant to the proper authority . On April 14 , 1971 , the date the notice was issued , Mr. Alvarez L. LeCesne was the Chief , Notices Section , Audit Division , Los Angeles District . The incumbent of that position was authorized by ...
... pursuant to the proper authority . On April 14 , 1971 , the date the notice was issued , Mr. Alvarez L. LeCesne was the Chief , Notices Section , Audit Division , Los Angeles District . The incumbent of that position was authorized by ...
Page 25
... pursuant to Rule 122 , Tax Court Rules of Practice and Procedure . The stipulation of facts and the exhibits attached thereto are incorporated herein by reference and are found accordingly . Harry C. Keeler and Geraldine L. Keeler ...
... pursuant to Rule 122 , Tax Court Rules of Practice and Procedure . The stipulation of facts and the exhibits attached thereto are incorporated herein by reference and are found accordingly . Harry C. Keeler and Geraldine L. Keeler ...
Page 29
... pursuant to sections 1301 through 1305 in the same taxable year . Decision will be entered for the respondent . BERCY INDUSTRIES , INC . , AND SUBSIDIARIES , PETITIONER V. COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket No. 5879-76 ...
... pursuant to sections 1301 through 1305 in the same taxable year . Decision will be entered for the respondent . BERCY INDUSTRIES , INC . , AND SUBSIDIARIES , PETITIONER V. COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket No. 5879-76 ...
Page 31
... pursuant to a plan and agreement of reorganization among Beverly , Beverly Manor , Old Bercy , and the shareholders of Old Bercy , Old Bercy merged into Beverly Manor . Beverly Manor , the surviving corporation , pursuant to the merger ...
... pursuant to a plan and agreement of reorganization among Beverly , Beverly Manor , Old Bercy , and the shareholders of Old Bercy , Old Bercy merged into Beverly Manor . Beverly Manor , the surviving corporation , pursuant to the merger ...
Page 37
... pursuant to section 368 ( a ) ( 2 ) ( D ) .12 However section 368 ( a ) ( 2 ) ( D ) is only of use if Old Bercy's assets could have been conveniently transferred to petitioner . Therefore , as previously noted , to codify and liberal ...
... pursuant to section 368 ( a ) ( 2 ) ( D ) .12 However section 368 ( a ) ( 2 ) ( D ) is only of use if Old Bercy's assets could have been conveniently transferred to petitioner . Therefore , as previously noted , to codify and liberal ...
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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.