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. |
From inside the book
Results 1-5 of 100
Page 55
... held on De- cember 27 , 1945 , that arrangements to make the conveyances involved in the program for liquidation of the corporation had not been com- pleted , whereupon the meeting was adjourned to January 11 , 1946 . At the meeting held ...
... held on De- cember 27 , 1945 , that arrangements to make the conveyances involved in the program for liquidation of the corporation had not been com- pleted , whereupon the meeting was adjourned to January 11 , 1946 . At the meeting held ...
Page 81
... Held , on authority of Roebling v . Commissioner , 143 Fed . ( 2d ) 810 , that in addition to the statutory merger and to constitute a " reorganization " within the Federal income tax statutes , the trans- action must meet the test of ...
... Held , on authority of Roebling v . Commissioner , 143 Fed . ( 2d ) 810 , that in addition to the statutory merger and to constitute a " reorganization " within the Federal income tax statutes , the trans- action must meet the test of ...
Page 145
... held , and accordingly represented an interest different from that which the stock previously held represented . In the Circuit Court of Appeals for the Ninth Circuit we were reversed , the court being of the view that we had ...
... held , and accordingly represented an interest different from that which the stock previously held represented . In the Circuit Court of Appeals for the Ninth Circuit we were reversed , the court being of the view that we had ...
Page 146
... held ; that the distribution , being one of property rights varying in character from those previously owned , the dividend in preferred shares constituted income ; and that the opinion of the Supreme Court in the Koshland case was ...
... held ; that the distribution , being one of property rights varying in character from those previously owned , the dividend in preferred shares constituted income ; and that the opinion of the Supreme Court in the Koshland case was ...
Page 149
... held class A shares and class B shares in the above stated ratio ; and that in the case of those who held both classes of stock , but not in that ratio , the taxable distribution was limited to that portion of the distributions ...
... held class A shares and class B shares in the above stated ratio ; and that in the case of those who held both classes of stock , but not in that ratio , the taxable distribution was limited to that portion of the distributions ...
Other editions - View all
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.