Reports of the Tax Court of the United States, Volume 6U.S. Government Printing Office, 1947 - Taxation |
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Page 19
... securities , or the transaction of any business carried on for gain or profit , or gains or profits and income derived from any Source whatever . have blocked the purchase of the policy and thus left ( 14 ) 19 ALFRED COWLES .
... securities , or the transaction of any business carried on for gain or profit , or gains or profits and income derived from any Source whatever . have blocked the purchase of the policy and thus left ( 14 ) 19 ALFRED COWLES .
Page 33
United States. Tax Court. depreciation that may arise by reason of holding such securities . In making investments and reinvestments , however , my said trustees shall invest trust funds in securities in which trustees are authorized to ...
United States. Tax Court. depreciation that may arise by reason of holding such securities . In making investments and reinvestments , however , my said trustees shall invest trust funds in securities in which trustees are authorized to ...
Page 35
... securities in the market , the firm of F. E. Hutton & Co. acting as stockbroker . Upon the occasion of filing the corporation's first Federal tax return , Coe consulted his attorney , who went with him to engage the services of one ...
... securities in the market , the firm of F. E. Hutton & Co. acting as stockbroker . Upon the occasion of filing the corporation's first Federal tax return , Coe consulted his attorney , who went with him to engage the services of one ...
Page 36
... Securities Corporation , 39 B. T. A. 1103 ; affd . per curiam , 116 Fed . ( 2d ) 800 ; cf. Dayton Bronze Bearing Co. v . Gilligan , 281 Fed . 709 ; C. R. Lindback Foundation , 4 T. C. 652 ; affd . per curiam , Fed . ( 2d ) — ( C. C. A. ...
... Securities Corporation , 39 B. T. A. 1103 ; affd . per curiam , 116 Fed . ( 2d ) 800 ; cf. Dayton Bronze Bearing Co. v . Gilligan , 281 Fed . 709 ; C. R. Lindback Foundation , 4 T. C. 652 ; affd . per curiam , Fed . ( 2d ) — ( C. C. A. ...
Page 43
... securities or real estate other than in shares of stock or obligations of petitioner or any subsidiary of the petitioner . This " Committee " was composed of three persons , named and so desig- nated , of which the president of ...
... securities or real estate other than in shares of stock or obligations of petitioner or any subsidiary of the petitioner . This " Committee " was composed of three persons , named and so desig- nated , of which the president of ...
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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...