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 7
... effect rather than its language , for terms used in it are legally incompatible . Thus the cash advance for production costs is referred to as a loan in the fifth paragraph , but as an investment in the sev- enth . Intent , however , is ...
... effect rather than its language , for terms used in it are legally incompatible . Thus the cash advance for production costs is referred to as a loan in the fifth paragraph , but as an investment in the sev- enth . Intent , however , is ...
Page 16
... effect . The further inconsistency arises that although in Poe v . Seaborn , supra , the Supreme Court subsequently relieved the husband of tax- ation on the wife's theoretical share of Washington community income , it did so in large ...
... effect . The further inconsistency arises that although in Poe v . Seaborn , supra , the Supreme Court subsequently relieved the husband of tax- ation on the wife's theoretical share of Washington community income , it did so in large ...
Page 9
... EFFECT.- The taxpayer is entitled to accelerated amortization of emergency plant facilities in accordance with an election under section 124 , I. R. C. , where the taxpayer and the Commissioner entered into a closing agreement under ...
... EFFECT.- The taxpayer is entitled to accelerated amortization of emergency plant facilities in accordance with an election under section 124 , I. R. C. , where the taxpayer and the Commissioner entered into a closing agreement under ...
Page 51
... effect of the contract was simply to vest petitioner with a right to 60 per cent of Controlair's net profits in consideration of the use of space rent - free . And petitioner did not even contribute the space , although it agreed to do ...
... effect of the contract was simply to vest petitioner with a right to 60 per cent of Controlair's net profits in consideration of the use of space rent - free . And petitioner did not even contribute the space , although it agreed to do ...
Page 80
... effect for tax purposes as though each constituted a distinct transaction . * And with- out regard to whether the result is imposition or relief from taxation , the courts have recognized that where the essential nature of a transaction ...
... effect for tax purposes as though each constituted a distinct transaction . * And with- out regard to whether the result is imposition or relief from taxation , the courts have recognized that where the essential nature of a transaction ...
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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.