Reports of the Tax Court of the United States, Volume 6U.S. Government Printing Office, 1947 - Taxation |
From inside the book
Results 1-5 of 100
Page 41
... contract for 1940 was 33.2 years , and for the year 1941 , 32.5 years . The amount of the annuity purchased is a ... contract , nor were they delivered individ- ual contracts . The purchase of the annuity contract was authorized by the ...
... contract for 1940 was 33.2 years , and for the year 1941 , 32.5 years . The amount of the annuity purchased is a ... contract , nor were they delivered individ- ual contracts . The purchase of the annuity contract was authorized by the ...
Page 49
... contract the company agreed to pay to his designated beneficiary ( or survivor ) a certain sum as a " death benefit . " During the first three years that sum is the amount of the premium or consideration paid for the contract and ...
... contract the company agreed to pay to his designated beneficiary ( or survivor ) a certain sum as a " death benefit . " During the first three years that sum is the amount of the premium or consideration paid for the contract and ...
Page 50
... contract ; where the payments were cash bonuses paid for services actu- ally rendered ; or where some absolute benefit has been conferred upon the employee in the form of a true annuity or life insurance contract . Cf. Commissioner v ...
... contract ; where the payments were cash bonuses paid for services actu- ally rendered ; or where some absolute benefit has been conferred upon the employee in the form of a true annuity or life insurance contract . Cf. Commissioner v ...
Page 51
... contract he has no present vested interest in the annuity , nor is the employer obligated under a definite pension plan , constituting a provision of its contract of em- ployment , to make any further payments in future years increasing ...
... contract he has no present vested interest in the annuity , nor is the employer obligated under a definite pension plan , constituting a provision of its contract of em- ployment , to make any further payments in future years increasing ...
Page 174
... contract with the Texas Co. , hereinafter referred to as Texas , concerning said lands . Under the terms of the contract or agreement , petitioner reserved to itself an oil and gas royalty of one - fourth of the oil and gas produced ...
... contract with the Texas Co. , hereinafter referred to as Texas , concerning said lands . Under the terms of the contract or agreement , petitioner reserved to itself an oil and gas royalty of one - fourth of the oil and gas produced ...
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Common terms and phrases
agreed agreement amount annuity assets assignment bank basis beneficiary benefit bonds capital stock cash certiorari Chertoff claims COMMISSIONER OF INTERNAL computing contends contract corporation corpus cost Court death debentures decedent decedent's December 29 December 31 decision deduction deficiency determined disallowed distribution dividends Docket earnings employees entitled excess profits tax executed expenses filed FINDINGS OF FACT follows fund gift gift tax gross income Haldeman held Helen Alexander Helvering hereinafter Herschbach Howell income tax income tax returns interest Internal Revenue Code investment issue lease liability liquidation ment mortgage net income October 21 operation paid parties partnership payable payment percent period peti petitioner petitioner's preferred stock principal prior purchase purpose received respect respondent Revenue Act section 23 securities shares statute stipulated stockholders supra taxable taxpayer thereof Thurlim tion tioner transfer trust estate trust instrument Turpentine wife
Popular passages
Page 83 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...
Page 287 - All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually rendered; traveling expenses (including the entire amount expended for meals and lodging) while away from home in the pursuit of a trade or business...
Page 254 - 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 19 - Income which is to be distributed currently by the fiduciary to the beneficiaries, and income collected by a guardian of an infant which is to be held or distributed as the court may direct...
Page 191 - ... (B) in a taxable year beginning after December 31, 1935, by a corporation in connection with a reorganization, then the basis shall be the same as it would be in the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year in which the transfer was made.
Page 83 - 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 452 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 191 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...
Page 509 - ... has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be taxed as a gain from the exchange of property.
Page 451 - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...