Reports of the Tax Court of the United States, Volume 14U.S. Government Printing Office, 1950 - Law reports, digests, etc Final issue of each volume includes table of cases reported in the volume. |
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Page 80
... constituted a distinct transaction . * And with- out regard to whether the result is imposition or relief from taxation , the courts have recognized that where the essential nature of a transaction is the acquisi- tion of property , it ...
... constituted a distinct transaction . * And with- out regard to whether the result is imposition or relief from taxation , the courts have recognized that where the essential nature of a transaction is the acquisi- tion of property , it ...
Page 86
... constituted a purchase by petitioner of the assets of Peoples as determined and herein contended by respondent , or , as contended by petitioner , constituted a " reorganization " within the meaning of that term as defined by subsection ...
... constituted a purchase by petitioner of the assets of Peoples as determined and herein contended by respondent , or , as contended by petitioner , constituted a " reorganization " within the meaning of that term as defined by subsection ...
Page 88
... constituted a sale because such notes were the equivalent of cash and the transferor did not acquire a sufficiently definite " interest in the affairs of the purchasing company " ; in Helvering v . Minnesota Tea Co. , 296 U. S. 378 ...
... constituted a sale because such notes were the equivalent of cash and the transferor did not acquire a sufficiently definite " interest in the affairs of the purchasing company " ; in Helvering v . Minnesota Tea Co. , 296 U. S. 378 ...
Page 129
... constituted a retention by decedent of the right to designate those members of his family whom he desired to receive income of the trust and the amounts each was to receive . It was a right to designate beneficiaries of the trust and ...
... constituted a retention by decedent of the right to designate those members of his family whom he desired to receive income of the trust and the amounts each was to receive . It was a right to designate beneficiaries of the trust and ...
Page 145
... constituted in- come . In that view , we were affirmed by the Circuit Court of Appeals for the Second Circuit , the Circuit Court holding that , even though the situation presented was different from that presented in the Koshland v ...
... constituted in- come . In that view , we were affirmed by the Circuit Court of Appeals for the Second Circuit , the Circuit Court holding that , even though the situation presented was different from that presented in the Koshland v ...
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Common terms and phrases
acquired adjusted agreement amount Archbold-Hagner assets average base period basis beneficiaries bonds cash cent certificates claimed COMMISSIONER OF INTERNAL common stock compensation computed contract corporation Court death decedent decedent's December 28 December 31 deductions deficiency determined distribution dividend Docket earnings employees entitled estate tax excess profits tax expenses Fageol Feldman filed FINDINGS OF FACT fiscal follows Funk gift tax gross estate gross income Hall-Scott held Helen Saunders Helvering included income tax interest Internal Revenue Code issued January liability mortgage Northern Trust Co operation paid partners partnership patents payable payment pension period net income peti petitioner petitioner's prior proration purchase purpose receipt received renegotiation respect respondent salary Seagram section 107 section 722 shares Spar stipulated stockholders supra taxable taxpayer thereof tion tioner transfer trust trust instrument United wife York
Popular passages
Page 370 - Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived...
Page 203 - If an exchange would be within the provisions of subsection (b), (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 203 - 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 332 - person" shall be construed to mean and include an individual, a trust, estate, partnership, association, company or corporation. (2) Partnership and partner. The term "partnership...
Page 663 - ... 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 (1) the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Page 296 - The basis upon which exhaustion, wear and tear, and obsolescence are to be allowed in respect of any property shall be the adjusted basis provided in section 113 (b) for the purpose of determining the gain upon the sale or other disposition of such property.
Page 179 - Upon the sale or exchange of property the entire amount of the gain or loss, determined under section 111, shall be recognized, except as hereinafter provided in this section.
Page 144 - Intervals, then, to the extent that It Is paid or credited or to be distributed out of Income from property, it shall be...
Page 673 - ... 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.