Reports of the Tax Court of the United States, Volume 21U.S. Government Printing Office, 1954 - Taxation |
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Page 14
... result was reached on the theory that the tax- payer there retained , among other assets , a claim under section 722 for excess profits tax relief . Such result was held to be the proper one despite the fact that the stockholders ...
... result was reached on the theory that the tax- payer there retained , among other assets , a claim under section 722 for excess profits tax relief . Such result was held to be the proper one despite the fact that the stockholders ...
Page 35
... result . In this respect I view the wording of the leg- islation and its history as less noncommital than does the present opinion . The disallowance is of " deductions *** attributable to a trade or business carried on by " the ...
... result . In this respect I view the wording of the leg- islation and its history as less noncommital than does the present opinion . The disallowance is of " deductions *** attributable to a trade or business carried on by " the ...
Page 47
... result of purchase of a proven tract or lease , and if the fair market value of the property is materially disproportionate to the cost . Section 114 ( b ) ( 2 ) of the Code , as of the applicable date , is printed in the margin.1 1 SEC ...
... result of purchase of a proven tract or lease , and if the fair market value of the property is materially disproportionate to the cost . Section 114 ( b ) ( 2 ) of the Code , as of the applicable date , is printed in the margin.1 1 SEC ...
Page 48
... was therefore unknown to , and was not dis- covered by Richfield as a result of Ricco's investigation and report . We are also satisfied that the deposit was not discovered 48 ( 40 ) 21 TAX COURT OF UNITED STATES REPORTS .
... was therefore unknown to , and was not dis- covered by Richfield as a result of Ricco's investigation and report . We are also satisfied that the deposit was not discovered 48 ( 40 ) 21 TAX COURT OF UNITED STATES REPORTS .
Page 52
... result thereof , deficiencies in tax and interest were assessed against the settlors and , correspondingly , overassess- ments of tax and credits for interest thereon were determined with respect to each of the petitioner - trusts for ...
... result thereof , deficiencies in tax and interest were assessed against the settlors and , correspondingly , overassess- ments of tax and credits for interest thereon were determined with respect to each of the petitioner - trusts for ...
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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.