Reports of the Tax Court of the United States, Volume 30U.S. Government Printing Office, 1959 - Law reports, digests, etc |
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Page 10
... INTERNAL REVENUE , RESPONDENT . SPINDLER METAL PROCESSING Co. , PETITIONER , v . COMMISSIONER OF INTERNAL REVENUE ... Code of 1939 , as follows : Docket No. Year Kind of tax 1944 58828 ( Income 10 ( 1 ) 30 TAX COURT OF UNITED STATES REPORTS .
... INTERNAL REVENUE , RESPONDENT . SPINDLER METAL PROCESSING Co. , PETITIONER , v . COMMISSIONER OF INTERNAL REVENUE ... Code of 1939 , as follows : Docket No. Year Kind of tax 1944 58828 ( Income 10 ( 1 ) 30 TAX COURT OF UNITED STATES REPORTS .
Page 32
... tax convention and is not intended to relate in any way to the possibly wider meaning accorded to the word " business " in some of the provisions of the Internal Revenue Code . In view of the foregoing it is unnecessary for us to ...
... tax convention and is not intended to relate in any way to the possibly wider meaning accorded to the word " business " in some of the provisions of the Internal Revenue Code . In view of the foregoing it is unnecessary for us to ...
Page 33
... Internal Revenue Code are applicable to the facts of this case . Raymond C. Cushwa , Esq . , and George D. Webster , Esq . , for the petitioners in Docket Nos . 63499 and 63500 . Gustave F. Straub , Esq . , for the petitioner in Docket ...
... Internal Revenue Code are applicable to the facts of this case . Raymond C. Cushwa , Esq . , and George D. Webster , Esq . , for the petitioners in Docket Nos . 63499 and 63500 . Gustave F. Straub , Esq . , for the petitioner in Docket ...
Page 41
... tax relief under section 722 of the Internal Revenue Code of 1939 for the years 1940 through 1945 . The issues presented for decision are whether petitioner is qualified for such relief by reason of the fact that it was committed prior ...
... tax relief under section 722 of the Internal Revenue Code of 1939 for the years 1940 through 1945 . The issues presented for decision are whether petitioner is qualified for such relief by reason of the fact that it was committed prior ...
Page 69
... INTERNAL REVENUE , RESPONDENT . Docket No. 57943. Filed April 17 , 1958 . Held , that under the facts of this case ... Revenue Code . James D. Conway , Esq . , for the petitioner . Richard C. McLaughlin , Esq . , for the respondent ...
... INTERNAL REVENUE , RESPONDENT . Docket No. 57943. Filed April 17 , 1958 . Held , that under the facts of this case ... Revenue Code . James D. Conway , Esq . , for the petitioner . Richard C. McLaughlin , Esq . , for the respondent ...
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Common terms and phrases
acquired additional agreed agreement Allis Corporation allowed amount assets bank base period basis Bausch & Lomb beneficiary bonds capital gain cash cent cigarette paper claimed common stock Company computing contract cost Court debts decedent December 31 deduction deficiency depreciation directors distribution dividends Docket earnings employees entitled excess profits tax expenses Federal filed FINDINGS OF FACT follows franchise gross income held hereinafter Hoguet income tax income tax return installment interest Internal Revenue Code issue J. I. Morgan January lease liability loan ment mill mortgage net income ordinary income paid parties payable payments peti petitioner petitioner's preferred stock prior production pulp purchase purposes pursuant quartzite received rental respect respondent determined respondent's Riggs section 23 sell shareholders shares sold stipulated stockholders supra taxable taxpayer tion tioner trade or business transaction transfer Trianon trust trust instrument United wife
Popular passages
Page 128 - All other property acquired after marriage by either husband or wife, or both, including real property situated in this state, and personal property wherever situated, heretofore or hereafter, acquired while domiciled elsewhere, which would not have been the separate property of either if acquired while domiciled in this state, is community property...
Page 312 - In the case of mines, oil and gas wells, other natural deposits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case...
Page 939 - For purposes of this section, the term "collapsible corporation" means a corporation formed or availed of principally for the manufacture, construction, or production of property, for the purchase of property which (In the hands of the corporation) is...
Page 228 - An exemption of $50,000; (b) In the case of a nonresident, by deducting from the value of that part of his gross estate which at the time of his death is situated in the United States...
Page 312 - In the case of property held in trust, the allowable deduction shall be apportioned between the income beneficiaries and the trustee in accordance with the pertinent provisions of the instrument creating the trust, or, in the absence of such provisions, on the basis of the trust income allocable to each.
Page 30 - permanent establishment" when used with respect to an enterprise of one of the contracting parties means a branch, management, factory or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or has a stock of merchandise from which he regularly fills orders on its behalf.
Page 528 - 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 597 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 372 - ... such timber, and the adjusted depletion basis thereof, shall be considered as though it were a gain or loss, as the case may be, on the sale of such timber.
Page 693 - The liability, at law or in equity, of a transferee of property of a taxpayer, in respect of the tax (including interest, additional amounts, and additions to the tax provided by law) imposed upon the taxpayer by this title or by any prior income, excess-profits, or war-profits tax Act.