Reports of the Tax Court of the United States, Volume 14U.S. Government Printing Office, 1950 - Law reports, digests, etc Final issue of each volume includes table of cases reported in the volume. |
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Results 1-5 of 100
Page 1
... contends that in organization and operation it bears in- sufficient resemblance to a corporation to warrant its classification as such for tax purposes . It also contests liability for the penalties , alleging reasonable cause for its ...
... contends that in organization and operation it bears in- sufficient resemblance to a corporation to warrant its classification as such for tax purposes . It also contests liability for the penalties , alleging reasonable cause for its ...
Page 11
... contends that under Washington law all of the income for the taxable years from the 950 - acre farm which he inherited from his brother and from the 90 - acre tract which he and his wife purchased in 1941 was community income ...
... contends that under Washington law all of the income for the taxable years from the 950 - acre farm which he inherited from his brother and from the 90 - acre tract which he and his wife purchased in 1941 was community income ...
Page 90
... contends that such continuing pro- prietary interest in the transferee corporation measured by the 16.4 per cent of its common stock should be regarded as substantial enough to meet the continuity of interest test . We think it should ...
... contends that such continuing pro- prietary interest in the transferee corporation measured by the 16.4 per cent of its common stock should be regarded as substantial enough to meet the continuity of interest test . We think it should ...
Page 106
... contends that the New York State tax of $ 2,896.94 in- curred in the year 1942 but paid in 1943 should be deductible from gross income in computing his victory tax net income for the taxable year 1943. In the alternative , he contends ...
... contends that the New York State tax of $ 2,896.94 in- curred in the year 1942 but paid in 1943 should be deductible from gross income in computing his victory tax net income for the taxable year 1943. In the alternative , he contends ...
Page 144
... contend that the well established and controlling test for making such a determination is whether the distribution did ... contends that the real and proper test is not solely as to whether the stock distribution effected a change in the ...
... contend that the well established and controlling test for making such a determination is whether the distribution did ... contends that the real and proper test is not solely as to whether the stock distribution effected a change in the ...
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Common terms and phrases
acquired adjusted agreement amount Archbold-Hagner assets average base period basis beneficiaries bonds cash cent certificates claimed COMMISSIONER OF INTERNAL common stock compensation computed contract corporation Court death decedent decedent's December 28 December 31 deductions deficiency determined distribution dividend Docket earnings employees entitled estate tax excess profits tax expenses Fageol Feldman filed FINDINGS OF FACT fiscal follows Funk gift tax gross estate gross income Hall-Scott held Helen Saunders Helvering included income tax interest Internal Revenue Code issued January liability mortgage Northern Trust Co operation paid partners partnership patents payable payment pension period net income peti petitioner petitioner's prior proration purchase purpose receipt received renegotiation respect respondent salary Seagram section 107 section 722 shares Spar stipulated stockholders supra taxable taxpayer thereof tion tioner transfer trust trust instrument United wife York
Popular passages
Page 370 - Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived...
Page 203 - If an exchange would be within the provisions of subsection (b), (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 203 - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...
Page 332 - person" shall be construed to mean and include an individual, a trust, estate, partnership, association, company or corporation. (2) Partnership and partner. The term "partnership...
Page 663 - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death (1) the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Page 296 - The basis upon which exhaustion, wear and tear, and obsolescence are to be allowed in respect of any property shall be the adjusted basis provided in section 113 (b) for the purpose of determining the gain upon the sale or other disposition of such property.
Page 179 - Upon the sale or exchange of property the entire amount of the gain or loss, determined under section 111, shall be recognized, except as hereinafter provided in this section.
Page 144 - Intervals, then, to the extent that It Is paid or credited or to be distributed out of Income from property, it shall be...
Page 673 - ... shall be the same as it would be in the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year in which the transfer was made.