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Securities (Continued)

Dealers in (Continued)

Inventories, 555, 846

Inventory basis changed, 379
Inventory method permitted, 378
Inventory valuation, "market value"
basis, 1319

Losses on sale of securities, 847
Officers of corporation dealing in, not,
555

Partnerships as, deductions for, loss,
854

Valuation of securities, 846
Defined, 409

Determination of fair market value, 486
Distribution in partnership dissolution, 445
Distribution in reorganization, 385
Distribution of, in reorganization, two-
year requirement, 553
Dividends paid in, 636
Exchange,

By controlled corporation for property,
407-411

Former procedure, 408, 409, 410
For other property, 418

For securities, 407

Former procedure, 407

Exchanges in reorganization, 384
Exempt (See "Exempt Securities")
Foreign money not, 856

Fractional shares, 458

French stamps on foreign securities al-
lowable deduction, 1193

Gain from taxable distributions, in reor-
ganization taxed, 645

Gain or loss from sale (See Gain or Loss
from Sale")

Held for resale by other than dealer,
inventories not permitted, 556

Held in bailment, loss from embezzlement
deductible, 883

Inventoried shrinkage deductible only by
dealers, 846
Inventories,

Bank with department dealing in, 380
Permitted dealers, 553, 846

Issuance of, corporate losses on, 885-891
Losses, issuance or redemption of, 885-
891

Non-productive, as, 562

Non-taxable (See "Exempt Securities")
Payment of estate debts, 403

Redemption of, corporate losses on, 885-
891

Reorganization,

Distributed without surrender of hold-
ings, 480

Distribution of new without surrender
of old, 422

Distribution of, not distribution of earn-
ings, 428

Exchange with "boot," 423-427
Taxable if sold, 425

Restriction on exchange in reorganization,

417

Former procedure, 417, 418
"Short" sales, 451

Securities (Continued)

Sold to employees or stockholders under
market value, 451

Transfer to proprietorship name not sale,

403

Valuation, 523-524

Average of stock quotations on March
1, 1913, 524

Owned by decedents, 523
When variously purchased, 441
Value at date available, 831
Worthless,

Austrian bonds not, 848
Deductions, 849

German bonds not, 848

Indemnification under agreement, not a
loss, 852

Purchased by stockholders not deduct-
ible, 917

Written down to a nominal value as,

850

Security (See "Collateral")

Selling Expense, Deductible from gross in-

come from business, 314

Servants (See "Domestic Servants")
Shade Trees, Damage to, deductions al-
lowed, 880

Sheriff, Excess of allowance of feeding
prisoners, exempt, 208

Shipments, Charter money freight, exemp-
tion of, 1181

Shipowners' Mutual Protection and In-
demnity Association,
Receipts exempt, 227

Rents, interest and dividends taxable, 227
Taxable income, 1302

Shipping Board, Ships requisitioned, depre-
ciation, 1004

Shipping Industry, Depreciation, 1003
Ships (See "Vessels")

Shipwreck, Losses deductible, 842, 880
Shoe Manufacturers, Depreciation, 1004
Short Sales,

Capital gain or loss not permitted, 557
Gain or loss, 853

Gain or loss basis, 451

Inventories, basis for dealers, 380

Inventory method, when applicable to, 379
Not "hedges," 379

Who is entitled to dividends, 636

Sickness, Compensation for, returns of in-
formation not required, 174

Signatures, Facsimile, use of by banks and
trust companies, 180

Signs, Depreciation, 1005

Silk Industry, Inventions, average cost
method not permitted, 363
Silver Mines, Depletion unit, 1100

Singer, Throat specialist's bills not deduct-
ible, 730

Single Person (See "Unmarried Person")
Sinking Funds,

Increment as income, 599

Mines, 1074

Payments by lessee not income, 623
Slander, Compensation for not income, 203
Soap Industry, Depreciation, 1005

Social Clubs,
Exempt, 29

Profits taxable, 29

"Social" Expenses, Not deductible, 736
Social Service Organizations, Gifts de-
ductible, 1137

Society, Repurchasing interests of resigned
or deceased members, exempt, 29
Society for the Prevention of Cruelty to
Animals or Children (See "Preven-
tion")

Soil, Restoration of fertility as capital
charge, 754

Soldier, Non-resident alien, 1163
Sole Proprietorship,

Dissolution of corporation not always
effected by change to, 76

Taxable year, one basis for all sources of
income, 50

Sole Stockholder, Corporation, losses of

corporation not deductible in personal
returns, 851

Source, Payment of Tax at (See "Pay-
ment of Tax at Source")

South Carolina, Income tax, accrual, 816
Spanish Language, Association for promo-
tion of, exempt, 25

Special Assessment Districts, As political
subdivisions of state or territory, 218
Special Assessments (See "Assessments,
Special")

Special Bank Examiner, Liquidating bank,
returns, 82

Special Counsel to City, Compensation tax-
able, 292

Special Counsel to State Comptroller,

Salary exempt, 208

Special Deputy Bank

Examiners and

Clerks, Washington, Salaries exempt,
208

Special Investigator of State Prohibition
Violations, Compensation taxable, 292
Special Partnerships, California, as part-
nerships, 8

Special Tax Investigator, Compensation
taxable, 292

Speculation (See also "Margin," "Securi-

ties, Dealers in," "Short Sales,"
"Stock Exchange," "Stocks")

As trade or business, 899

Dealers in securities distinguished from,
379

Loss in, deduction allowed, 858

Former procedure, 858

Speculator, Capital gains may be claimed
by, 379

Spouse (See "Husband and Wife")
Sprinkler System, Depreciation, 1005
Stable Equipment, Depreciation, 1005
Stamp Taxes,

Deductible, 819

From gross income, 815

Stamps, Use of by banks and trust com-
panies, 180

State Agricultural Colleges, Employees,
salaries exempt, 208

State Banks, Assessments, as capital invest-
ments, 852

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Ownership certificates not required, 176
Taxable income paid by, returns of in-
formation, 174

Statistics, Tax, publication of, 92
Status of Taxpayers (See "Change of
Status")

Statute of Limitations (See "Limitation
Period")

Statutory Net Loss (See "Net Loss")
Steamship Association, exempt, 27
Steamship Company,

Non-resident alien, allocation of income.
1177

When not considered doing business in
the U. S., 1181

Stock (See also "Capital Stock," "Common
Stock," "Dividends," "Margins," "Pre-
ferred Stock," "Securities," "Stock
Rights," "Treasury Stock")
Acquired through rights, two-year require-
ment, 554

Assessments not deductible, 852

Stock-(Continued)

Assumption of tax liability with purchase,

837

Bank (See "Banks, Stock")

Basis reduced by distributions not out of

profits, 651

Bonus, 445

Income taxable, 689

Bonus in credited but not available, 253
Building and loan associations, valuation
of, 600

Cancellation or redemption, 448

Compensation for personal services in,
Taxable, 284, 300, 307, 630
Valuation, 300, 303

Compensation in, deductibility, 772
Contributions by stockholders as addition
to capital, 329

Distribution in reorganization, 335
Dividends (See "Dividends," "Stock Divi-
dends")

Donated, no gain or loss from sale, 331
Escrow,

Dividends subject to normal tax, 303
Valuation, 303

"Essentially equivalent to taxable divi-
dend," 448

Exchanged for stock, 407

Exchange for voting trust certificates, 403
Exchanges in reorganization, 384
Forfeited subscriptions, taxable, 333
Inventoried shrinkage not deductible, 847
Issued for less than par, liability of sub-
scriber, 332

Issued on invention, valuation, 301
purchase of customer's

Loss through

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Possible without proof of market value,
489

Probable future profits considered, 499
Stock vs. assets, 495

When closely held, 496

Voting stock controls, 409
Worthless,

At a nominal price, 847
Establishment of, 849
Loss an ordinary loss, 847
Not a capital asset, 557

Stock Bonus Fund, Distributions to em-
ployees from, returns of information at
source, 173

Stock Brokers (See also "Securities, Deal-
ers in")

Commissions not deductible, 771

Commissions paid to, as capital deductions,
561

Payments to customer, returns of infor-
mation not required, 174

Returns of information of accounts, 167
Stock Dividends (See Table of Contents,
p. 626)

Allocation between life-tenant and re-
mainderman, taxable status, 691

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Taxability to life-tenants in general, 690

Former procedure, 690

Two-year requirement, 554

Stock Exchanges,

Initiation fee deductible, 789

Listing fee not deductible, 745
Loss on sale of seat, deductible, 879
Market value as established by, 492

Stocks Exchanges-(Continued)

Not a business league, chamber of com-
merce or board of trade, 28
Taxable, 28

Stock Fire Insurance Company, As mutual
fire insurance company, 1506
Stock-in-trade,

Depletion allowances not permitted, 556
Depreciation allowances not permitted, 556
Determination of, 556
Not capital asset, 554

Not included in capital assets, 551

Real property owned by dealers, 555
Stock Rights,

Acquired through, two-year requirement,
554

Gain or loss from sale, 395

Former procedure, 395

Not dividends, 629

Owned by decedent, 1234

Sale, 443-445

Former procedure, 443

Sale above rate on exchange, 445

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Stockholders -(Continued)

Stock bought below market value, 451
Tax on bank stock not deductible by, 838
Former procedure, 839

Undistributed corporate profits, alterna-
tive method of taxing, 1154

Voluntary assessments, not taxable, 328
Stockholders' Protective Committee, In-
spection of returns not permitted to, 88
Storage,

Oil loss from, 1096

Returns of information at source not re-
quired for, 174

Storage Charges, Illegal seizure of liquor,
not deductible, 880

Storms,

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Subsidy,

Paid to manufacturer, when income arises,
318

Paid to railroad not taxable, 325
Suits at Law (See also "Attorneys")
Expenses arising from illegal transactions,
796

Recoveries from claims in litigation, 322
Returns,

Copies furnished for, 90, 91

Originals furnished as evidence in, 89
Production not compulsory in, 91
Use of figures obtained from inspection
of returns not permitted for, 89
Sunday, Taxes due on, 159

Superintendent of Water Works, Salary
exempt, 209

Supper Money, Not taxable, 308

Surgeon, Paid by state industrial commis-

sion, compensation taxable, 292
Surplus (See also "Profits, Undistributed")
Accruing in years prior to 1918, not re-
duced by accruing obsolescence, 1028
Accumulated prior to March 1, 1913,
stock dividend from, 664
Determination of, 644

Dividends should not be declared from
capital in absence of, 652

March 1, 1913, effect of stock dividend
on, 642

Reasonable, 1150

Surtax (See also "Exempt Income")

Accrued interest on War Savings Cer-
tificates, when exempt, 611

Application of, 3

Point of, 126

Basis of, 3

Cash dividends joint stock land bank sub-
ject to, 220

Credits against net income not per-
mitted, 113, 127

Credit for taxes paid at source, 198
Debtor corporation of tax-free covenant
bond not liable for bondholder's, 193
Deductions, application of to, 201
Dividends exempt, certain, 220

Dividends exempt from normal tax but
subject to, 646

Dividends of individuals subject to, 4
Dividends subject to normal and, 645

Former procedure, 645

Evasion through transfer to trust, 402
Exemptions, total possible on obligations
of the U. S., 610

Federal Land Bank Bonds, exempt, 613
Foreign partnerships not doing business
in the U. S., not subject to, 607
Imposed upon net income, 238
Interest,

Accrued on war savings certificates,
taxable, 610

Exempt from, certain, 217

Interest on certain obligations of the
U. S.,

Exempt from, 607
Subject to, 607

Items subject to, 238

Liability for, 126

Surtax-(Continued)

Liberty bond interest,

Certain subject to, 607

Foreign corporations not doing business
in U. S. not subject to, 607

Non-resident aliens not subject to, 607
National Farm Loan Associations, exempt,
613

Non-resident aliens, 1160

Obligations of the U. S.,

Limited exemption for, 610
Subject to, 609
Partners, 676

Penalty for evasion through undistributed
profits, 1149

Former procedure, 1149

Personal service corporation, dividends ex-
empt to distributee, 111
Former procedure, 111

Rate, 126, 127

Former procedure, 128

Sale of mineral deposits reduced because
of discovery value, 129

Specific credit for interest on,

Obligations of the U. S. which are sub-
ject to, 122

Taxpayer subject, only to, claim filed re-
garding tax-free covenant bonds, 193
Treasury certificates of indebtedness, 613
Treasury notes issued under Victory Lib-
erty Loan Act, subject to, 609

Undistributed corporate profits (See
Table of Contents, 1149)

Victory Notes not subject to, 607
Surveys, Should cost be capitalized, 751
Sword, Cost deductible, 736
Syndicate Agreement,

As joint venture, 7
Syndicates,

As associations, 13
Deductions,

Capital contribution of member, 7
Expenses, 7

Gain or loss, allocation to, members, 7
Member,

Reduction of capital contribution pro-
rated, 7

Taxable for income from, 7

Not associations, 13

T

Table of Cases (See separate index)
Tax Board (See "United States Board of
Tax Appeals")

Tax Collector (See "Collector of Internal
Revenue")

Taxable Year (See also "Calendar Year,"
"Fiscal Year")

Accounting period recognized as, 49

Affiliated corporations having different
fiscal years, 102

Changed accounting period recognized as,
51

Debts must be charged off within, 938
Definition, 47, 938

Estate or trust and beneficiary differ, 702
Fractional part of year as, 47

Recognition of accounting period as, 49

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