Reports of the Tax Court of the United States, Volume 80U.S. Government Printing Office, 1983 - Taxation |
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Results 1-5 of 80
Page 23
... gift , contribution to capital , or the like , the cost basis of property might not be equal to the value received by the seller . See Majestic Securities Corp. v . Commissioner , 120 F.2d 12 ( 8th Cir . 1941 ) , affg . 42 B.T.A. 698 ...
... gift , contribution to capital , or the like , the cost basis of property might not be equal to the value received by the seller . See Majestic Securities Corp. v . Commissioner , 120 F.2d 12 ( 8th Cir . 1941 ) , affg . 42 B.T.A. 698 ...
Page 191
... Gifts , par . 79.2 , p . 79- 6 ( 1981 ) . In this regard , section 1.482-1 ( b ) ( 3 ) , Income Tax Regs . , 94We should not be understood to imply that we necessarily agree with petitioners that Estero possessed the three corporate ...
... Gifts , par . 79.2 , p . 79- 6 ( 1981 ) . In this regard , section 1.482-1 ( b ) ( 3 ) , Income Tax Regs . , 94We should not be understood to imply that we necessarily agree with petitioners that Estero possessed the three corporate ...
Page 208
... Gifts , par . 31.1.2 , at 31-8 / 9 ( 1981 ) . Accordingly we have not addressed that issue but rather have confined ourselves to the issue of substance over form . 109See also Hale v . Commissioner , T.C. Memo . 1965-274 , 24 T.C.M. ...
... Gifts , par . 31.1.2 , at 31-8 / 9 ( 1981 ) . Accordingly we have not addressed that issue but rather have confined ourselves to the issue of substance over form . 109See also Hale v . Commissioner , T.C. Memo . 1965-274 , 24 T.C.M. ...
Page 214
... Gifts , par . 42.2 , at 42-6 ( 1981 ) ( " the primary function of IRC §266 is to authorize the Treasury to permit carrying charges to be capitalized " ) . And , as we have already shown , that section does not grant cash - basis ...
... Gifts , par . 42.2 , at 42-6 ( 1981 ) ( " the primary function of IRC §266 is to authorize the Treasury to permit carrying charges to be capitalized " ) . And , as we have already shown , that section does not grant cash - basis ...
Page 219
... gift / part - sale transfer of ordinary income property was determined by the fair market value of the property at the time of the transfer , reduced by the proceeds received . Secs . 1.170-0 and 1.170-1 ( c ) ( 1 ) , Income Tax Regs ...
... gift / part - sale transfer of ordinary income property was determined by the fair market value of the property at the time of the transfer , reduced by the proceeds received . Secs . 1.170-0 and 1.170-1 ( c ) ( 1 ) , Income Tax Regs ...
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Common terms and phrases
9th Cir acquired adjustment affd agreement allocation Alps Corp amount application assets bank basis benefit bonds bonus Brewer's Island California capital carryback cash Champlin claimed Commissioner contract corporation Court debt decedent deduction distribution district earnings easement Estero exchange exemption expenses fact fair market value Federal income tax filed fiscal Foster Bayou Foster City Foster Enterprises Foster partnership GRFF Hoblitzelle Foundation Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service investment issue Jack Foster Kroger land lease liability Likins-Foster loan notice of deficiency operating loss paid parties partner payments percent petitioner petitioner's prior profits purposes pursuant qualified real property received record reinsurance rental Rept Republic National Bank respondent's rule San Mateo County section 482 shareholders shares specific supra T.C. Memo taxable income taxpayer tion trade or business transfer trust U.S. dollar United Westway
Popular passages
Page 142 - ... in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 141 - The legal right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid them, by means which the law permits, cannot be doubted.
Page 1066 - Receipts of shipowners' mutual protection and Indemnity associations; Dividends from China Trade Act corporations; Compensation of employees of foreign governments. (c) Inventories. — Whenever In the opinion of the Commissioner the use of Inventories is necessary In order clearly to determine the Income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best...
Page 188 - In contravention of the agreement between the partners, where the circumstances do not permit a dissolution under any other provision of this section, by the express will of any partner at any time...
Page 845 - In determining his income tax. each partner shall take into account separately his distributive share of the partnership's...
Page 501 - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 300 - Basically, the question in each case is whether the facts alleged, under all the circumstances, show that there is a substantial controversy, between parties having adverse legal interests, of sufficient immediacy and reality to warrant the issuance of a declaratory judgment.
Page 774 - In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material incomeproducing factors...
Page 555 - 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...
Page 849 - An assignee for the benefit of creditors or any person appointed by the court shall have the right to enforce the contributions specified in clause (d) of this paragraph.