Reports of the U.S. Board of Tax Appeals, Volume 27U.S. Government Printing Office, 1933 - Taxation |
From inside the book
Results 1-5 of 100
Page 115
... supra , or Cortland Specialty Co. , supra . Those cases are now pending in the Supreme Court , writ of certi- orari having been granted , and , assuming that the Board and the Circuit Courts will be affirmed in both cases , I do not ...
... supra , or Cortland Specialty Co. , supra . Those cases are now pending in the Supreme Court , writ of certi- orari having been granted , and , assuming that the Board and the Circuit Courts will be affirmed in both cases , I do not ...
Page 153
... supra , the court said : We required a consolidated return for the first period of ten months , during part of which two affiliates were alone , and a separate return for the second period of two months during which the " parent " was ...
... supra , the court said : We required a consolidated return for the first period of ten months , during part of which two affiliates were alone , and a separate return for the second period of two months during which the " parent " was ...
Page 154
... supra ; American Paper Exports , Inc. v . Bowers , supra . In Automatic Fire Alarm Co. of New York , supra , we said : * There was no period in 1920 for which the Delaware company was liable to file a return of its separate income . At ...
... supra ; American Paper Exports , Inc. v . Bowers , supra . In Automatic Fire Alarm Co. of New York , supra , we said : * There was no period in 1920 for which the Delaware company was liable to file a return of its separate income . At ...
Page 169
... supra , the court observes as follows : It is elementary that the mere declaration of a dividend does not constitute either a dividend or a distribution . Before there can be a dividend there must be a declaration of such by the proper ...
... supra , the court observes as follows : It is elementary that the mere declaration of a dividend does not constitute either a dividend or a distribution . Before there can be a dividend there must be a declaration of such by the proper ...
Page 174
... supra . Based on this decision of the Circuit Court of Appeals , which was not available to us prior to the promulgation of our report , the petitioner in due season filed a motion with the Board to reconsider our report , which motion ...
... supra . Based on this decision of the Circuit Court of Appeals , which was not available to us prior to the promulgation of our report , the petitioner in due season filed a motion with the Board to reconsider our report , which motion ...
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Other editions - View all
Common terms and phrases
acquired agreement allowed amount assessment assets Bamberger Bank basis Board bonds capital stock cash cent claimed COMMISSIONER OF INTERNAL common stock computing contract corporation cost court death decedent decedent's December 31 decision deduction deficiency depreciation determined Director distribution Docket Executors expenses February 28 filed FINDINGS OF FACT follows fund gain or loss gross income held included income tax income tax return interest INTERNAL REVENUE investment issue J. A. Folger January lease Lessee Lessor liability liquidation March net income opinion paid pany par value parties partnership payment period peti petitioner petitioner's Poncin preferred stock prior proceeding profits Promulgated purchase Railway Company real estate Realty received respect respondent respondent's Revenue Act securities sold Southern Railway Southern Railway Company statute stipulation stockholders supra taxable income taxpayer thereof tion tioner transaction transfer Tribune Company trust trust instrument United Western Union wife
Popular passages
Page 399 - 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 374 - 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 73 - 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 68 - 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 819 - 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 17 - 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 325 - That the value of the gross estate of the decedent shall be determined by including the value at the time of his death...
Page 230 - ... (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 165 - 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 473 - 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.