Reports of the Tax Court of the United States, Volume 30U.S. Government Printing Office, 1959 - Taxation |
From inside the book
Results 1-5 of 97
Page 27
... resident of the United Kingdom shall not be deemed to be engaged in trade or business in the United States unless he or she " has a permanent establishment situated therein . " 1 The petition alleges error in connection with the entire ...
... resident of the United Kingdom shall not be deemed to be engaged in trade or business in the United States unless he or she " has a permanent establishment situated therein . " 1 The petition alleges error in connection with the entire ...
Page 32
... resident [ of the United Kingdom ] may elect for any taxable year to be subject to United States tax as if such resident were engaged in trade or business in the United States . " an interest in such property , derived from sources ...
... resident [ of the United Kingdom ] may elect for any taxable year to be subject to United States tax as if such resident were engaged in trade or business in the United States . " an interest in such property , derived from sources ...
Page 33
... resident of the United Kingdom who is *** not en- gaged in trade or business in the United States . " If the ownership and leasing of real property were considered to constitute a trade or business , that provision would be meaningless ...
... resident of the United Kingdom who is *** not en- gaged in trade or business in the United States . " If the ownership and leasing of real property were considered to constitute a trade or business , that provision would be meaningless ...
Page 35
... resident of Philadelphia , Pennsyl- vania , filed his Federal income tax return for 1947 with the then col- lector of internal revenue for the first district of Pennsylvania . The 1947 return of Mary B. Warburton , who died November 17 ...
... resident of Philadelphia , Pennsyl- vania , filed his Federal income tax return for 1947 with the then col- lector of internal revenue for the first district of Pennsylvania . The 1947 return of Mary B. Warburton , who died November 17 ...
Page 75
... residence . From September 22 , 1951 , to July 17 , 1952 , inclusive , the petitioner advanced the ad- ditional sum of $ 50,081.29 , all of which was paid in full as of Decem- ber 31 , 1952 , by the conveyance of the Kerr Farm to ...
... residence . From September 22 , 1951 , to July 17 , 1952 , inclusive , the petitioner advanced the ad- ditional sum of $ 50,081.29 , all of which was paid in full as of Decem- ber 31 , 1952 , by the conveyance of the Kerr Farm to ...
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Common terms and phrases
acquired additional agreed agreement Allis Corporation allowed amount assets bank basis Bausch & Lomb beneficiary bonds capital gain cash cent cigarette paper claimed common stock Company computing contract cost Court decedent decedent's December 31 deduction deficiency depreciation directors disallowed distribution dividends Docket earnings employees entitled excess profits tax expenses filed FINDINGS OF FACT follows franchise gross income held hereinafter Hoguet income tax income tax return installment interest Internal Revenue Code issue J. I. Morgan January lease liability loan ment mill mortgage net income ordinary income paid parties partnership payable payments peti petitioner petitioner's preferred stock prior production pulp purchase purposes pursuant quartzite received rental respect respondent determined respondent's Riggs section 23 sell shareholders shares sold stipulated stockholders supra taxable taxpayer tion tioner trade or business transaction transfer Trianon trust trust instrument United wife
Popular passages
Page 312 - In the case of property held in trust, the allowable deduction shall be apportioned between the income beneficiaries and the trustee in accordance with the pertinent provisions of the instrument creating the trust, or, in the absence of such provisions, on the basis of the trust income allocable to each.
Page 664 - State of , do hereby certify that [1st party named], personally known to me to be the same person whose name is subscribed to the foregoing instrument, appeared before me this day in person and acknowledged that he signed, sealed, and delivered the said instrument as his free and voluntary act, for the uses and purposes therein set forth, including the release and waiver of the right of homestead.
Page 873 - 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 312 - In the case of property held by one person for life with remainder to another person, the deduction shall be computed as if the life tenant were the absolute owner of the property and shall be allowed to the life tenant.
Page 230 - An exemption of $50,000; (b) In the case of a nonresident, by deducting from the value of that part of his gross estate which at the time of his death is situated in the United States...
Page 511 - ... (B) as paid-in surplus or as a contribution to capital, then the basis shall be the same as it would be in the hands of the transferor...
Page 278 - ... income of the estate or trust the amount of the income of the estate or trust for its taxable year which is to be distributed currently...
Page 539 - paid or incurred" and "paid or accrued" shall be construed according to the method of accounting upon the basis of which the net income is computed under section 212 or 232. The deductions and credits provided for in this title shall be taken for the taxable year in which "paid or accrued
Page 835 - If the property was acquired by bequest, devise, or inheritance, or by the decedent's estate from the decedent, the basis shall be the fair market value of such property at the time of such acquisition.
Page 759 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include 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...