Reports of the Tax Court of the United States, Volume 30U.S. Government Printing Office, 1959 - Law reports, digests, etc |
From inside the book
Results 1-5 of 100
Page 23
... necessary for us to examine the trust instru- ments from that standpoint . The Commissioner argues that petitioners ' contributions to their trusts were made pursuant to plans deferring the receipt of com- pensation . Petitioners ...
... necessary for us to examine the trust instru- ments from that standpoint . The Commissioner argues that petitioners ' contributions to their trusts were made pursuant to plans deferring the receipt of com- pensation . Petitioners ...
Page 39
... NECESSARY FOR ADJUSTMENT.— ( 2 ) CORRECTION NOT BARRED AT TIME OF ERRONEOUS ACTION.— ( A ) DETERMINATION DESCRIBED IN SECTION 1312 ( 3 ) ( B ) .— In the case of a determination described in section 1312 ( 3 ) ( B ) ( relating to certain ...
... NECESSARY FOR ADJUSTMENT.— ( 2 ) CORRECTION NOT BARRED AT TIME OF ERRONEOUS ACTION.— ( A ) DETERMINATION DESCRIBED IN SECTION 1312 ( 3 ) ( B ) .— In the case of a determination described in section 1312 ( 3 ) ( B ) ( relating to certain ...
Page 50
... necessary and advisable for the corpora- tion to embark upon a program of expansion and a program to meet the con- tingency of a failure of the supply of raw materials and that certain steps had already been taken in that connection ...
... necessary and advisable for the corpora- tion to embark upon a program of expansion and a program to meet the con- tingency of a failure of the supply of raw materials and that certain steps had already been taken in that connection ...
Page 58
... necessary to operate it . The major reason petitioner committed itself in 1939 to increase its capacity for production by the addition of machine No. 5 was that petitioner was convinced that by the time it received machine No. 5 , it ...
... necessary to operate it . The major reason petitioner committed itself in 1939 to increase its capacity for production by the addition of machine No. 5 was that petitioner was convinced that by the time it received machine No. 5 , it ...
Page 95
... necessary business expense , not only because that amount was required to be paid in order for it to have the privileges of the club but also because there was no assurance that any part of the cost would ever be repaid to it . The ...
... necessary business expense , not only because that amount was required to be paid in order for it to have the privileges of the club but also because there was no assurance that any part of the cost would ever be repaid to it . The ...
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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.