Reports of the Tax Court of the United States, Volume 30U.S. Government Printing Office, 1959 - Taxation |
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Results 1-5 of 100
Page 34
... respect to an enterprise of one of the contracting parties means a branch , management , factory or other fixed place of business , but does not include an agency unless the agent has , and habitually exercises , a general authority to ...
... respect to an enterprise of one of the contracting parties means a branch , management , factory or other fixed place of business , but does not include an agency unless the agent has , and habitually exercises , a general authority to ...
Page 40
... respect to which the tax was not paid but which is includible in the gross income of the taxpayer for another taxable year or in the gross income of a related taxpayer . Here the determination in the related cases involving the ...
... respect to which the tax was not paid but which is includible in the gross income of the taxpayer for another taxable year or in the gross income of a related taxpayer . Here the determination in the related cases involving the ...
Page 42
... respect to the taxable year of the determination and which is adopted in the determination is inconsistent with erro- neous exclusion of the disputed item in the taxable year of the error . Petitioners here maintained just such an ...
... respect to the taxable year of the determination and which is adopted in the determination is inconsistent with erro- neous exclusion of the disputed item in the taxable year of the error . Petitioners here maintained just such an ...
Page 79
... respect to such allegation shall- ( 1 ) if notification has not been sent in accordance with subsection ( b ) , be on the Secretary or his delegate , or ( 2 ) if the taxpayer has submitted the statement described in subsection ( c ) ...
... respect to such allegation shall- ( 1 ) if notification has not been sent in accordance with subsection ( b ) , be on the Secretary or his delegate , or ( 2 ) if the taxpayer has submitted the statement described in subsection ( c ) ...
Page 124
... respect of fraud , and , unlike the evidence with respect to the original failure to file returns , we think the evidence in respect of the so - called delinquent returns does not convincingly show that they were false or fraudulent ...
... respect of fraud , and , unlike the evidence with respect to the original failure to file returns , we think the evidence in respect of the so - called delinquent returns does not convincingly show that they were false or fraudulent ...
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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...