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 29
... loss . Petitioner carried back net operating loss to the pre - reorganiza- tion taxable income of T. Held , the transaction does not qualify as a ( B ) , ( E ) , or ( F ) reorganization and , accordingly , pursuant to sec . 381 ( b ) ...
... loss . Petitioner carried back net operating loss to the pre - reorganiza- tion taxable income of T. Held , the transaction does not qualify as a ( B ) , ( E ) , or ( F ) reorganization and , accordingly , pursuant to sec . 381 ( b ) ...
Page 33
... loss . The loss was incurred in connection with the same business activity which was formerly conducted by Old Bercy.5 Thereafter petitioner filed an application for a tentative carryback adjustment , pursuant to section 6411 ...
... loss . The loss was incurred in connection with the same business activity which was formerly conducted by Old Bercy.5 Thereafter petitioner filed an application for a tentative carryback adjustment , pursuant to section 6411 ...
Page 34
... loss to a taxable year of the transferor ( acquired ) corporation . Specifically , 381 ( b ) ( 3 ) does not apply in the case of an acquisition in connection with a ( B ) , ( E ) , or ( F ) reorganization . Sec . 1.381 ( a ) -1 ( b ) ...
... loss to a taxable year of the transferor ( acquired ) corporation . Specifically , 381 ( b ) ( 3 ) does not apply in the case of an acquisition in connection with a ( B ) , ( E ) , or ( F ) reorganization . Sec . 1.381 ( a ) -1 ( b ) ...
Page 38
... loss under section 172 could be carried back regardless of the label put on the type of reorganization . " Aetna Casualty & Surety Co. v . United States , 568 F.2d 811 ( 2d Cir . 1976 ) , rehearing denied 568 F.2d at 823 ( 2d Cir . 1977 ) ...
... loss under section 172 could be carried back regardless of the label put on the type of reorganization . " Aetna Casualty & Surety Co. v . United States , 568 F.2d 811 ( 2d Cir . 1976 ) , rehearing denied 568 F.2d at 823 ( 2d Cir . 1977 ) ...
Page 39
... losses and , of Old and New Aetna , or by construing sec . 381 ( b ) ( 3 ) somewhat narrowly so as to be inapplicable to this particular reorganization . Either way , a loss carry back favored by the policies of the Code , see secs ...
... losses and , of Old and New Aetna , or by construing sec . 381 ( b ) ( 3 ) somewhat narrowly so as to be inapplicable to this particular reorganization . Either way , a loss carry back favored by the policies of the Code , see secs ...
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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...