Reports of the United States Tax Court, Volume 70United States Tax Court, 1978 - Government publications Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
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Results 1-5 of 100
Page 40
... death and they are includable in his gross estate pursuant to sec . 2035 , I.R.C. 1954 , although they are at the same time deductible as charitable transfers under sec . 2055. The consequence of including these gifts in the gross ...
... death and they are includable in his gross estate pursuant to sec . 2035 , I.R.C. 1954 , although they are at the same time deductible as charitable transfers under sec . 2055. The consequence of including these gifts in the gross ...
Page 41
... death , after which he was succeeded as president by his wife , Florence . Decedent executed his will on May 23 , 1967. In substance , he left $ 25,000 to his son and grandchildren and the remainder of his probate estate to his wife ...
... death , after which he was succeeded as president by his wife , Florence . Decedent executed his will on May 23 , 1967. In substance , he left $ 25,000 to his son and grandchildren and the remainder of his probate estate to his wife ...
Page 42
... death , the trust corpus be divided into two parts , one a marital trust funded only to the extent necessary to secure the decedent's estate the maximum marital deduction allowable , and the second a nonmarital trust , which was to ...
... death , the trust corpus be divided into two parts , one a marital trust funded only to the extent necessary to secure the decedent's estate the maximum marital deduction allowable , and the second a nonmarital trust , which was to ...
Page 43
... death of cancer on July 10 , 1972 , at the age of 84. He was terminally ill throughout the 3 - year period immediately preced- ing his death . Decedent remained lucid and in good spirits until the final weeks of his life . Nonetheless ...
... death of cancer on July 10 , 1972 , at the age of 84. He was terminally ill throughout the 3 - year period immediately preced- ing his death . Decedent remained lucid and in good spirits until the final weeks of his life . Nonetheless ...
Page 44
... death within section 2035 , I.R.C. 1954 , it is the computation of the marital deduction that is in fact the principal matter that is central to this litigation . Ordinarily , it would be of no practical consequence whether gifts to ...
... death within section 2035 , I.R.C. 1954 , it is the computation of the marital deduction that is in fact the principal matter that is central to this litigation . Ordinarily , it would be of no practical consequence whether gifts to ...
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Common terms and phrases
9th Cir acquired affd agreement allocated amended amount annuity apply Arthur Smith assets Atlas Bank basis benefit capital carryback cash claimed COMMISSIONER OF INTERNAL community property contract Corp corporation Court decedent decedent's December December 31 decision distribution dividends divorce employee entitled estate tax exempt expenses facts fair market value Federal income tax fees filed franchise funds gross income Hayden Stone held Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service issue KBSI liability loan loss Malag marital deduction notice of deficiency operating organization paid parties partnership payable payments percent period petition petitioner petitioner's players prior proceeds profits purchase purposes pursuant qualified received regulations reorganization Rept respect Respondent determined RESPONDENT Docket respondent's Rule shareholders shares statutory stipulated supra taxable taxpayer transaction transfer trust trust instrument United Yawata
Popular passages
Page 176 - In the case of a series of transactions, the date of the last such transaction) ; and (B) stock of the distributing corporation possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
Page 6 - For the production or collection of income; (2) For the management, conservation, or maintenance of property held for the production of income; or (3) ln connection with the determination, collection, or refund of any tax.
Page 585 - To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or "(c) To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person, in connection with the purchase or sale of any security.
Page 1048 - ... means wages, salaries, or professional fees, and other amounts received as compensation for personal services actually rendered, but does not include that part of the compensation derived by the taxpayer for personal services rendered by him to a corporation which represents a distribution of earnings or profits rather than a reasonable allowance as compensation for the personal services actually rendered.
Page 82 - While the question of dependency may involve principles of law, the fact remains that dependency is a question of fact to be determined from all the circumstances of the case and the burden of proving it rests upon him who claims it.
Page 519 - ... (3) an organization which — (A) is organized, and at all times thereafter is operated, exclusively for the benefit of, to perform the functions of, or to carry out the purposes of...
Page 917 - ... taxes assessed against local benefits of a kind tending to increase the value of the property assessed...
Page 369 - An individual who is legally separated from his spouse under a decree of divorce or of separate maintenance shall not be considered as married...
Page 706 - Payments for the use or occupancy of rooms or other space where services are also rendered to the occupant, such as for the use or occupancy of rooms or other quarters in hotels, boarding houses, or apartment houses furnishing hotel services, or in tourist camps or tourist homes, or payments for the use or occupancy of space in parkin? lots, warehouses, or storage garages, do not constitute rentals from real estate; consequently, such payments are included in determining net earnings from self-employment.
Page 569 - An order striking out pleadings or parts thereof, or staying further proceedings until the order is obeyed, or dismissing the action or proceeding or any part thereof, or rendering a judgment by default against the disobedient party...