Reports of the Tax Court of the United States, Volume 4U.S. Government Printing Office, 1945 - Law reports, digests, etc |
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Page 57
... cost of redemption would be determined as follows : The amount paid by the purchaser , plus 10 percent of that amount , which was immediately added thereto ; a further sum computed at the rate of 10 percent per annum on the amount paid ...
... cost of redemption would be determined as follows : The amount paid by the purchaser , plus 10 percent of that amount , which was immediately added thereto ; a further sum computed at the rate of 10 percent per annum on the amount paid ...
Page 58
... costs so excessive as to detract materially from the value of the property . Petitioner's president submitted to its ... cost of the above designated prop . erties to be written off as of January 31 , 1941 out of the current earnings of ...
... costs so excessive as to detract materially from the value of the property . Petitioner's president submitted to its ... cost of the above designated prop . erties to be written off as of January 31 , 1941 out of the current earnings of ...
Page 66
... cost of the certificates computed without reference to lapse of time , a principle discussed above in connection ... cost of the certificate plus the 10 percent penalty , the income resulting from such interest for two years would ...
... cost of the certificates computed without reference to lapse of time , a principle discussed above in connection ... cost of the certificate plus the 10 percent penalty , the income resulting from such interest for two years would ...
Page 74
... cost of the property , where the obligation falls upon the vendee , and is to be capitalized . We hold , therefore , that the determination of the Commissioner in respect of this item was erroneous and that the petitioner is entitled to ...
... cost of the property , where the obligation falls upon the vendee , and is to be capitalized . We hold , therefore , that the determination of the Commissioner in respect of this item was erroneous and that the petitioner is entitled to ...
Page 85
... cost . The court then pointed out the following facts upon which , among others , it based its conclusion that the taxpayer was not writing insur- ance at cost : It charges the same rates as do the stock companies and pays the same ...
... cost . The court then pointed out the following facts upon which , among others , it based its conclusion that the taxpayer was not writing insur- ance at cost : It charges the same rates as do the stock companies and pays the same ...
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Common terms and phrases
accrued agreement Albert Fleming amended amount annuity applied assets Bank basis beneficiary cash claim COMMISSIONER OF INTERNAL common stock computing contract corporation corpus coupons Court death decedent decedent's December 31 decision deduction deficiency determined distribution dividends Docket earnings entitled estate tax excess profits tax executors expenses fair market value filed FINDINGS OF FACT follows funds gain Galbreath gift tax grantor gross estate gross income held Helvering hereinafter Hofford included income tax income tax return interest Internal Revenue Code investment issue January Lafayette College lease liability loss mortgage net income paid payable payment percent personal holding company peti petitioner petitioner's policies preferred stock principal prior purchase purpose question received refund respect respondent Revenue Act securities shares statute stipulated stockholders supra syndicate taxable taxpayer thereof tion tioner transfer trust estate trust instrument unjust enrichment wife
Popular passages
Page 247 - Gross Income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property ; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income...
Page 309 - ... traveling expenses (including the entire amount expended for meals and lodging) while away from home in the pursuit of a trade or business; and rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity...
Page 792 - ... (1) 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 807 - If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend...
Page 792 - Any transfer of a material part of his property in the nature of a final disposition or distribution thereof, made by the decedent within two years prior to his death without such a consideration, shall, unless shown to the contrary, be deemed to have been made in contemplation of death within the meaning of this title...
Page 544 - The respective interests of the husband and wife in community property during continuance of the marriage relation are present, existing and equal interests under the management and control of the husband as is provided in sections 172 and 172a of the Civil Code. This section shall be construed as defining the respective interests and rights of husband and wife in community property.
Page 430 - If a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income which he is required to return, even though it may still be claimed that he is not entitled to retain the money, and even though he may still be adjudged liable to restore its equivalent.
Page 219 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include — "(A) stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Page 44 - The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same provisions and limitations...
Page 178 - In the interpretation of statutes levying taxes, it is the established rule not to extend their provisions by implication beyond the clear import of the language used, or to enlarge their operations so as to embrace matters not specifically pointed out. In case of doubt, they are construed most strongly against the government, and in favor of the citizen.