Reports of the Tax Court of the United States, Volume 49U.S. Government Printing Office, 1968 - Taxation |
From inside the book
Results 1-5 of 80
Page 10
... meaning of section 453 ( d ) . Respondent argues that the formal assignment of the notes to the partnership must be disregarded as a sham ; that the petitioners should still be regarded as holders of the notes at the time of corporate ...
... meaning of section 453 ( d ) . Respondent argues that the formal assignment of the notes to the partnership must be disregarded as a sham ; that the petitioners should still be regarded as holders of the notes at the time of corporate ...
Page 11
... meaning- less maneuvers as are present here can be effective to eliminate any portion of the gain admittedly realized in the year of sale . It is per- fectly obvious that the assignment of the installment obligations to the partnership ...
... meaning- less maneuvers as are present here can be effective to eliminate any portion of the gain admittedly realized in the year of sale . It is per- fectly obvious that the assignment of the installment obligations to the partnership ...
Page 13
... meaning of section 453 ( d ) . We sustain the respondent on this issue . Decisions will be entered under Rule 50 . STATE FISH CORPORATION , PETITIONER V. COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket No. 1042-65 . Filed October ...
... meaning of section 453 ( d ) . We sustain the respondent on this issue . Decisions will be entered under Rule 50 . STATE FISH CORPORATION , PETITIONER V. COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket No. 1042-65 . Filed October ...
Page 15
... meaning of section 722 ( b ) ( 4 ) is based upon the authorization for and construction of three new generating plants and voluntary rate reductions made during the base period to increase sales . The application contained facts showing ...
... meaning of section 722 ( b ) ( 4 ) is based upon the authorization for and construction of three new generating plants and voluntary rate reductions made during the base period to increase sales . The application contained facts showing ...
Page 23
... meaning of section 722 ( b ) ( 4 ) of the Internal Revenue Code of 1939 as amended . OPINION TIETJENS , Judge : As indicated in the findings of fact petitioner's average base period net income for the purposes of computing its excess ...
... meaning of section 722 ( b ) ( 4 ) of the Internal Revenue Code of 1939 as amended . OPINION TIETJENS , Judge : As indicated in the findings of fact petitioner's average base period net income for the purposes of computing its excess ...
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Common terms and phrases
agreement amount apply assets attorney basis capital gains cash claim common stock community property contract corporation cost death decedent decedent's December December 31 decision decree deduction distribution district director Electric employee entitled estate tax exchange fair market value Federal income tax fees filed gift gift tax gross estate gross income Harriston Lumber held hereinafter income tax return incurred installment interest Internal Revenue Code issue January June June 30 lease liability liquidation litigation ment obligation operating loss opinion option ordinary and necessary ordinary income paid parties partnership payable payment percent period Perry peti petition petitioner petitioner's Pinsetter pinspotter Porter preferred stock prior purchase purpose receipts received record respect Respondent determined RESPONDENT Docket respondent's restricted stock shareholders shares statute stipulated stockholders supra tax return taxpayer tion tioner transaction transfer trust wife WJIV
Popular passages
Page 342 - 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 259 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment...
Page 143 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained 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...
Page 533 - Rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or Is not taking title or In which he has no equity.
Page 469 - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
Page 114 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
Page 665 - As used in this subsection, the term "security" means any bond, debenture, note, or certificate or other evidence of indebtedness, issued by any corporation (including one issued by a government or political subdivision thereof), with interest coupons or in registered form...
Page 178 - A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
Page 593 - Any transfer of a material part of his property in the nature of a final disposition or distribution thereof, made by the decedent within two years prior to his death without such a consideration, shall, unless shown to the contrary, be deemed to have been made in contemplation of death...
Page 519 - For the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including amounts paid for accident or health insurance) , or (B) For transportation primarily for and essential to medical care referred to in subparagraph (A).