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 13
... taxable years by petitioner Joseph E. Gilbert were taxable , but that the entire amount received is subject to tax , on the theory that he had in prior years collected more than his cost basis in the notes , leaving taxable the entire ...
... taxable years by petitioner Joseph E. Gilbert were taxable , but that the entire amount received is subject to tax , on the theory that he had in prior years collected more than his cost basis in the notes , leaving taxable the entire ...
Page 18
... taxable on the amount actually distributed to him , but contends that the trust , as a separate entity , is taxable on the bal- ance of $ 3,229.20 . The respondent contends that petitioner is taxable on the full $ 30,939.21 . Section ...
... taxable on the amount actually distributed to him , but contends that the trust , as a separate entity , is taxable on the bal- ance of $ 3,229.20 . The respondent contends that petitioner is taxable on the full $ 30,939.21 . Section ...
Page 19
... taxable , it will not be necessary to consider section 162 ( b ) . The respondent , in contending that petitioner is taxable on all the trust income under section 22 ( a ) , cites Mallinckrodt v . Nunan , 146 Fed . ( 2d ) 1 ; certiorari ...
... taxable , it will not be necessary to consider section 162 ( b ) . The respondent , in contending that petitioner is taxable on all the trust income under section 22 ( a ) , cites Mallinckrodt v . Nunan , 146 Fed . ( 2d ) 1 ; certiorari ...
Page 38
... taxable years 1940 and 1941 as follows : 1940 . 1941 . Year Income tax Declared value ] excess profits tax Excess profits tax $ 89,705 . 04 189,958 . 42 $ 18,737 . 64 $ 153 , 898. 69 103 , 455. 92 923 , 587.91 The contested issues are ...
... taxable years 1940 and 1941 as follows : 1940 . 1941 . Year Income tax Declared value ] excess profits tax Excess profits tax $ 89,705 . 04 189,958 . 42 $ 18,737 . 64 $ 153 , 898. 69 103 , 455. 92 923 , 587.91 The contested issues are ...
Page 45
... taxable years 1940 and 1941. No employee reported as income in the year 1941 the amount of the share or interest allocated to him or her in the $ 1,000,000 fund paid into a trust established by petitioner in that year . The amount of ...
... taxable years 1940 and 1941. No employee reported as income in the year 1941 the amount of the share or interest allocated to him or her in the $ 1,000,000 fund paid into a trust established by petitioner in that year . The amount 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...