Reports of the Tax Court of the United States, Volume 32U.S. Government Printing Office, 1960 - Law reports, digests, etc Final issue of each volume includes table of cases reported in the volume. |
From inside the book
Results 1-5 of 100
Page 18
... parties stipulate that from Sep- tember 8 , 1951 , petitioner was the holder and owner of 95 per cent of Hekor's outstanding stock , we must assume that by the use of the word " own " the parties meant to include beneficial ownership as ...
... parties stipulate that from Sep- tember 8 , 1951 , petitioner was the holder and owner of 95 per cent of Hekor's outstanding stock , we must assume that by the use of the word " own " the parties meant to include beneficial ownership as ...
Page 37
... parties to create a partnership relationship . 1 As a result of the agreements between Southwest and the upland owners , the latter endorsed Southwest's bid for a lease submitted to the State of California . Southwest was the only ...
... parties to create a partnership relationship . 1 As a result of the agreements between Southwest and the upland owners , the latter endorsed Southwest's bid for a lease submitted to the State of California . Southwest was the only ...
Page 39
... parties presented their evidence before a commissioner designated by this Court , and the findings of that commissioner have been served upon the parties in accordance with the Rules of this Court . The petitioner states in its reply ...
... parties presented their evidence before a commissioner designated by this Court , and the findings of that commissioner have been served upon the parties in accordance with the Rules of this Court . The petitioner states in its reply ...
Page 49
... parties under- stood that such was to be the effect of their agreement with relation to the change being made . The petitioner relies , in support of its position on this issue , upon Denver & Salt Lake Railway Co. , 24 T.C. 709. One of ...
... parties under- stood that such was to be the effect of their agreement with relation to the change being made . The petitioner relies , in support of its position on this issue , upon Denver & Salt Lake Railway Co. , 24 T.C. 709. One of ...
Page 124
... parties recognized that the primary issue is the applicability of section 117 ( m ) . The burden of proof upon this issue is upon the petitioners . Leland D. Payne , 30 T.C. 1044 , on appeal ( C.A. 5 ) , and Rose Sidney , 30 T.C. 1155 ...
... parties recognized that the primary issue is the applicability of section 117 ( m ) . The burden of proof upon this issue is upon the petitioners . Leland D. Payne , 30 T.C. 1044 , on appeal ( C.A. 5 ) , and Rose Sidney , 30 T.C. 1155 ...
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Common terms and phrases
16th amendment Adwood agreed agreement amendment amount AOTC applicable assessment assets bank base period basis capital gain cash cent claimed class B common Commissioner common stock computed construction contract corporation cost Court death decedent's December 31 deduction deficiency depreciation directors distribution dividend Docket Double Oaks equipment excess profits tax exchange expenses Federal filed fiscal follows Gratuity Fund gross income Hall held hereinafter included income tax income tax returns insurance company interest Internal Revenue Code inventory issue January June 30 lease loan loss ment mortgage net income operation ordinary income paid parties partnership Patenotre payment peti petitioner petitioner's preferred stock prior purchase purpose receipts received rent rental respect Respondent determined respondent's section 722 shares Sheldon Whitehouse sold Spring Co statute stipulated stockholders supra tankers taxable taxpayer tion tioner trade or business transfer trust United Venezuela Weatherford
Popular passages
Page 232 - ... rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity...
Page 515 - Property Used in the Trade or Business. — (1) Definition of property used in the trade or business. — For the purposes of this subsection, the term "property used in the trade or business...
Page 607 - ... (b) Sales of Realty and Casual Sales of Personalty. — In the case (1) of a casual sale or other casual disposition of personal property (other than 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), for a price exceeding $1,000...
Page 323 - If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend...
Page 788 - Where before the expiration of the time prescribed in section 275 for the assessment of the tax, both the Commissioner and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.
Page 130 - The net income shall be computed upon the basis of the taxpayer's annual accounting period (fiscal year or calendar year, as the case may be) in accordance with the method of accounting regularly employed in keeping the books of such taxpayer ; but if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income...
Page 102 - The fact that the earnings or profits of a corporation are permitted to accumulate beyond the reasonable needs of the business shall be determinative of the purpose to avoid surtax upon shareholders unless the corporation by the clear preponderance of the evidence shall prove to the contrary.
Page 621 - Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate...
Page 96 - If any corporation, however created or organized, is formed or availed of for the purpose of preventing the imposition of the surtax upon its shareholders through the medium of permitting its gains and profits to accumulate instead of being divided or distributed...
Page 615 - ... the acquisition by one corporation, in exchange solely for all or a part of its voting stock...