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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Page 11
... record which would permit us to make an allocation which would be more favorable to petitioner than the allocation made by respondent . According- ly , we sustain the allocation in the deficiency notice on the ground that petitioner has ...
... record which would permit us to make an allocation which would be more favorable to petitioner than the allocation made by respondent . According- ly , we sustain the allocation in the deficiency notice on the ground that petitioner has ...
Page 80
... record , it is clear that neither Mr. Scott nor his nephew intended that the nephew have any economic interest in the Trent River property during Mr. Scott's lifetime . The nephew provided no consideration for the life interest in the ...
... record , it is clear that neither Mr. Scott nor his nephew intended that the nephew have any economic interest in the Trent River property during Mr. Scott's lifetime . The nephew provided no consideration for the life interest in the ...
Page 83
... record that , from the time of the criminal indictment , Mr. Scott began systematically to dispose of his assets , placing them beyond the reach of his creditors . He had more than 30 years of experience in the roofing business and ...
... record that , from the time of the criminal indictment , Mr. Scott began systematically to dispose of his assets , placing them beyond the reach of his creditors . He had more than 30 years of experience in the roofing business and ...
Page 108
... record that the requirements of New Jersey law for statutory merger or consolidation were not satisfied here . Some confusion exists in certain cases involving statutory mergers or consolidations as to whether liability of the ...
... record that the requirements of New Jersey law for statutory merger or consolidation were not satisfied here . Some confusion exists in certain cases involving statutory mergers or consolidations as to whether liability of the ...
Page 109
... record that exceptions one , four , and five , so stated , have no application in this case . Fletcher remained in existence until it satisfied its own known liabilities . The transfer documents for the assets acquired by Atlas , which ...
... record that exceptions one , four , and five , so stated , have no application in this case . Fletcher remained in existence until it satisfied its own known liabilities . The transfer documents for the assets acquired by Atlas , which ...
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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 claim 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 gross income Hayden Stone held hereinafter 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 qualify 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 583 - ... organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or...
Page 174 - 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 4 - 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 416 - COMPULSORY COUNTERCLAIMS. A pleading shall state as a counterclaim any claim which at the time of serving the pleading the pleader has against any opposing party, if it arises out of the transaction or occurrence that is the subject matter of the opposing party's claim and does not require for its adjudication the presence of third parties of whom the court cannot acquire jurisdiction.
Page 998 - A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
Page 1030 - ... 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 32 - ... (D) A transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders immediately before the transfer), or any combination thereof, is in control of the corporation to which the assets are transferred; but only if, in pursuance of the plan, stock or securities of the corporation to which the assets are transferred are distributed in a transaction which...
Page 80 - 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 105 - The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same...
Page 899 - ... taxes assessed against local benefits of a kind tending to increase the value of the property assessed...