Reports of the Tax Court of the United States, Volume 21U.S. Government Printing Office, 1954 - Taxation |
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Page 7
... distribution to its sole stockholder on August 15 , 1945. Consequently , its sales of livestock for 1945 amounted to only $ 878.50 , which was not unusual since sales were normally made after August of each year . Its total reported ...
... distribution to its sole stockholder on August 15 , 1945. Consequently , its sales of livestock for 1945 amounted to only $ 878.50 , which was not unusual since sales were normally made after August of each year . Its total reported ...
Page 16
... distribution of a motion picture based on the story after certain costs of producing the picture had been paid . Held , in the circumstances of this case , the proportionate shares of the $ 100,000 received by the petitioners in 1946 ...
... distribution of a motion picture based on the story after certain costs of producing the picture had been paid . Held , in the circumstances of this case , the proportionate shares of the $ 100,000 received by the petitioners in 1946 ...
Page 20
... distribution of the contemplated motion picture , such payment to you , however , to be sub- ordinate to the liens of record resulting from the financing of the motion picture such as the bank , lab , etc. , and such amount to be paid ...
... distribution of the contemplated motion picture , such payment to you , however , to be sub- ordinate to the liens of record resulting from the financing of the motion picture such as the bank , lab , etc. , and such amount to be paid ...
Page 22
... distribution agreement under which Fox would release and distribute the picture to the public in return for a certain percentage of gross receipts as its fee . Fox was to act only as distributor , under a license agreement , and was not ...
... distribution agreement under which Fox would release and distribute the picture to the public in return for a certain percentage of gross receipts as its fee . Fox was to act only as distributor , under a license agreement , and was not ...
Page 24
... distribution of the film ; and Mutual , the owner , would be restored to 100 per cent ownership after the 7 - year licensing to United Artists for distribution purposes . The United Artists deal was never consummated because neither ...
... distribution of the film ; and Mutual , the owner , would be restored to 100 per cent ownership after the 7 - year licensing to United Artists for distribution purposes . The United Artists deal was never consummated because neither ...
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Common terms and phrases
acquired adjustments agreement allowed amount April assets average base period Bank basis bonds capital gain cash cent claimed coal COMMISSIONER OF INTERNAL Company computing contract corporation cost Court cream cheese debentures decedent December 31 decree deduction deficiency determined disallowed distribution dividend divorce Docket earnings excess profits credit excess profits tax expenses February 28 filed FINDINGS OF FACT follows gross income held included income tax income tax return interest Internal Revenue Code invested issue Jack Chesbro January June 30 Kraft Ill Lake Wales lease liability loss ment National Dairy net income operating ordinary income paid Pardon My Past parties partnership patents payable payments period net income peti petitioner petitioner's prior production purchase purpose received rental respondent respondent's salary section 722 shares sold stipulated stockholders supra taxpayer thereof tion tioner trade or business transferred trust United wife yeast
Popular passages
Page 83 - Deductions otherwise allowed by law not attributable to the operation of a trade or business regularly carried on by the taxpayer...
Page 301 - 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 828 - In the case of an Individual, losses sustained during the taxable year and not compensated for by insurance or otherwise — (1) U Incurred In trade or business; or (2) If Incurred in any transaction entered into for profit, though not connected with the trade or business...
Page 814 - This is not the substitution of the will of the judge for that of the legislator, for frequently words of general meaning are used in a statute, words broad enough to include an act in question, and yet a consideration of the whole legislation, or of the circumstances surrounding its enactment, or of the absurd results which follow from giving such broad meaning to the words, makes it unreasonable to believe that the legislator intended to include the particular act.
Page 8 - When aid to construction of the meaning of words, as used in the statute, is available, there certainly can be no "rule of law" which forbids its use, however clear the words may appear on "superficial examination.
Page 468 - ... as are allowed by the laws of the jurisdiction, whether within or without the United States, under which the estate is being administered...
Page 953 - ... organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, Including the encouragement of art and the prevention of cruelty to children or animals...
Page 278 - ... in discharge of, a legal obligation which, because of the marital or family relationship, is imposed upon or incurred by such husband under such decree or under a written instrument incident to such divorce...
Page 8 - Frequently, however, even when the plain meaning did not produce absurd results but merely an unreasonable one 'plainly at variance with the policy of the legislation as a whole' this Court has followed that purpose, rather than the literal words.
Page 47 - February 28, 1913, the basis for depletion shall be the fair market value of the property at the date of discovery or within thirty days thereafter, If such mines were not acquired as the result of purchase of a proven tract or lease, and If the fair market value of the property Is materially disproportionate to the cost.