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acquired additional agreed agreement allowed amount applied assessment assets authorized Bank basis Board bonds building capital cash cent City claimed Commissioner common stock Company computing consideration consolidated contends contract corporation cost court death decedent December decision deduction deficiency determined Director distribution dividend effect entered entitled evidence exchange expenses facts Federal filed FINDINGS follows fund gain gross held hold included income tax interest INTERNAL REVENUE investment involved issue January land lease liability liquidation loss March meaning notes operating opinion organized paid parties partnership payment period peti petitioner petitioner's preferred stock prior proceeding profits purchase question Railway reason received reported representing resident respect respondent Revenue Act rule securities shares sold statute stipulation stockholders supra taxable taxpayer thereof tion transaction transfer trust United wife
Page 389 - reorganization' means (A) a merger or consolidation (including the acquisition by one- corporation of at least a majority of the voting stock and at least a majority of the total number of shares of all other classes of stock of another corporation, or substantially all the properties of another corporation...
Page 364 - President of , the corporation described in and which executed the foregoing instrument; that he knows the seal of said corporation; that the seal affixed to said instrument is such corporate seal; that it was so affixed by order of the Board of Directors of said Corporation and that he signed his name thereto by like order.
Page 75 - If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend...
Page 70 - 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 809 - Future estates are either vested or contingent. They are vested, when there is a person in being, who would have an immediate right to the possession of the lands, upon the ceasing of the intermediate or precedent estate.
Page 19 - Farmers', fruit growers', or like associations organized and operated on a cooperative basis (a) for the purpose of marketing the products of members or other producers, and turning back to them the proceeds of sales, less the necessary marketing expenses...
Page 315 - That the value of the gross estate of the decedent shall be determined by including the value at the time of his death...
Page 222 - ... (b) Nonresident aliens. — All persons, in whatever capacity acting, including lessees or mortgagors of real or personal property, fiduciaries, employers, and all officers and employees of the United States, having the control, receipt, custody, disposal, or payment...
Page 157 - As used In this section the term " amounts distributed In partial liquidation " means a distribution by a corporation in complete cancellation or redemption of a part of its stock, or one of a series of distributions in complete cancellation or redemption of all or a portion of its stock.
Page 463 - If an exchange is described in paragraph (1) but has the effect of the distribution of a dividend, then there shall be treated as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as Is not In excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be treated as gain from the exchange of property.