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 12
... Internal Revenue Code of 1954 , as amended and in effect during the taxable years in issue . of subtitle D , it was not within the category 12 ( 1 ) 70 UNITED STATES TAX COURT REPORTS Decision will be entered for the respondent. ...
... Internal Revenue Code of 1954 , as amended and in effect during the taxable years in issue . of subtitle D , it was not within the category 12 ( 1 ) 70 UNITED STATES TAX COURT REPORTS Decision will be entered for the respondent. ...
Page 21
... effect on the date in question , all supervisors and their superiors ( with certain exceptions not relevant here ) were delegated the authority to designate an employee to serve as an acting supervisor during the supervisor's absence ...
... effect on the date in question , all supervisors and their superiors ( with certain exceptions not relevant here ) were delegated the authority to designate an employee to serve as an acting supervisor during the supervisor's absence ...
Page 23
... effect . This issue was not severed and remains for consideration at the trial of this case . " The Court has adequate authority to deal with a flagrant failure to proceed properly . See Rule 123 of the Court's Rules of Practice and ...
... effect . This issue was not severed and remains for consideration at the trial of this case . " The Court has adequate authority to deal with a flagrant failure to proceed properly . See Rule 123 of the Court's Rules of Practice and ...
Page 24
... Internal Revenue Code of 1954 , as amended and in effect during the taxable year at issue . ordinary income elements of lump - sum pension fund distribu- 24 ( 15 ) 70 UNITED STATES TAX COURT REPORTS Appropriate orders will be issued. ...
... Internal Revenue Code of 1954 , as amended and in effect during the taxable year at issue . ordinary income elements of lump - sum pension fund distribu- 24 ( 15 ) 70 UNITED STATES TAX COURT REPORTS Appropriate orders will be issued. ...
Page 27
... effect during the taxable year 1973 , which relates section 72 ( n ) ( 2 ) to certain distributions made only with respect to self- employed individuals . 6 Although section 1304 ( b ) ( 2 ) refers explicitly only to the inapplicability ...
... effect during the taxable year 1973 , which relates section 72 ( n ) ( 2 ) to certain distributions made only with respect to self- employed individuals . 6 Although section 1304 ( b ) ( 2 ) refers explicitly only to the inapplicability ...
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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...