Reports of the Tax Court of the United States, Volume 4U.S. Government Printing Office, 1945 - Law reports, digests, etc |
From inside the book
Results 1-5 of 100
Page 11
... excess was taxable as gain under section 22 ( a ) of the Internal Revenue Code , as interpreted in section 19.111-1 of Regulations 103. The petitioners allege in their petitions that no part of such excess constitutes taxable income and ...
... excess was taxable as gain under section 22 ( a ) of the Internal Revenue Code , as interpreted in section 19.111-1 of Regulations 103. The petitioners allege in their petitions that no part of such excess constitutes taxable income and ...
Page 13
... excess of the cost or other basis * of the stock on which declared . " Regulations under the 1924 , 1926 , 1928 , and 1932 Acts contained provisions to the same effect . Art . 1543 , Regulations 65 and 69 ; art . 643 , Regulations 74 ...
... excess of the cost or other basis * of the stock on which declared . " Regulations under the 1924 , 1926 , 1928 , and 1932 Acts contained provisions to the same effect . Art . 1543 , Regulations 65 and 69 ; art . 643 , Regulations 74 ...
Page 14
... excess from tax . Section 22 ( a ) of the 1938 Act defines gross income as including gains from dealings growing out of ownership in property or from any source whatever . Corresponding sections of prior acts contained like provisions ...
... excess from tax . Section 22 ( a ) of the 1938 Act defines gross income as including gains from dealings growing out of ownership in property or from any source whatever . Corresponding sections of prior acts contained like provisions ...
Page 15
... excess constitutes taxable gain . We find nothing in the statute , or its legislative history , disclosing congressional intent to go that far . The purpose of the 1924 amend- ment , as clearly shown by committee reports , was to ...
... excess constitutes taxable gain . We find nothing in the statute , or its legislative history , disclosing congressional intent to go that far . The purpose of the 1924 amend- ment , as clearly shown by committee reports , was to ...
Page 16
... excess of corporate distribution over basis shall be taxable ; but it is clearly provided that such is true only if the distribution is " not out of increase in value of property accrued before March 1 , 1913. " ( Italics sup- plied ...
... excess of corporate distribution over basis shall be taxable ; but it is clearly provided that such is true only if the distribution is " not out of increase in value of property accrued before March 1 , 1913. " ( Italics sup- plied ...
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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.