Reports of the Tax Court of the United States, 37. sējumsU.S. Government Printing Office, 1962 Final issue of each volume includes table of cases reported in the volume. |
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1.–5. rezultāts no 100.
13. lappuse
... supra . Whether or not a payment by a corporation to its stockholders is a distribution amounting to a dividend under section 115 ( a ) is primarily a question of fact . Lengs- field v . Commissioner , 241 F. 2d 508 ( C.A. 5 , 1957 ) ...
... supra . Whether or not a payment by a corporation to its stockholders is a distribution amounting to a dividend under section 115 ( a ) is primarily a question of fact . Lengs- field v . Commissioner , 241 F. 2d 508 ( C.A. 5 , 1957 ) ...
21. lappuse
... supra , relied upon by petitioner , does not , in my opinion , require a different conclusion . In that case the Court was concerned with the question as to what constituted a " limited period " as that phrase was used in Regulations ...
... supra , relied upon by petitioner , does not , in my opinion , require a different conclusion . In that case the Court was concerned with the question as to what constituted a " limited period " as that phrase was used in Regulations ...
22. lappuse
... supra . The resolutions authorizing the payments so stated . Nor , in my opinion , does Fifth Avenue Coach Lines , Inc. , supra , require a different conclusion . In that case petitioner's past presi- dent , Hugh J. Sheeran , had served ...
... supra . The resolutions authorizing the payments so stated . Nor , in my opinion , does Fifth Avenue Coach Lines , Inc. , supra , require a different conclusion . In that case petitioner's past presi- dent , Hugh J. Sheeran , had served ...
28. lappuse
... supra , but must coordinate , integrate , and construe them with section 311 ( a ) ( 2 ) and regulations section 1.311- ( 1 ) ( a ) , supra . Petitioner redeemed its notes for the specific purpose of preventing its stock from getting ...
... supra , but must coordinate , integrate , and construe them with section 311 ( a ) ( 2 ) and regulations section 1.311- ( 1 ) ( a ) , supra . Petitioner redeemed its notes for the specific purpose of preventing its stock from getting ...
37. lappuse
... supra . The second question is raised by the petitioners ' argument that the defendants in the Stricker litigation cannot be considered to have been defending their title because that suit was for an accounting between partners . In ...
... supra . The second question is raised by the petitioners ' argument that the defendants in the Stricker litigation cannot be considered to have been defending their title because that suit was for an accounting between partners . In ...
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accrual agreement amount applicable assets bank base period basis business expenses calcium carbonates capital gain cash certiorari City Savings claimed Clay Brown coal Commissioner Company computed conduit contract corporation cost Court debentures debt December December 31 deduction deficiency director of internal disallowed Docket duct electric employees excess profits tax expenditures Falstaff beer filed follows French Morocco gift tax gross income held hereinafter income tax return incurred installed interest Internal Revenue Code involved issue January Laneco lease liability loan loss March 11 McGraw Melvin ment Missisquoi notes operating ordinary and necessary ordinary income paid parties partnership payments percent peti petitioner petitioner's premium prior production purchase purpose receipt received regulations Reiner's residence respect Respondent determined respondent's shares sold stipulated stockholders supra taxpayer thereof tion tioner trade or business transaction trust United
Populāri fragmenti
863. lappuse - 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; but In the case of an exchange by two or more persons this paragraph shall apply only If the amount of the stock and securities received by each is substantially In proportion to his Interest in the property prior to the exchange.
863. lappuse - ... (6) TAX-FREE EXCHANGES GENERALLY. — If the property was acquired, after February 28, 1913, upon an exchange described in section 112 (b) to (e), inclusive, the basis shall be the same as in the case of the property exchanged, decreased in the amount of any money received by the taxpayer and increased in the amount of gain or decreased in the amount of loss to the taxpayer that was recognized upon such exchange under the law applicable to the year in which the exchange was made.
94. lappuse - 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...
66. lappuse - Between members of a family, as defined in paragraph (2) (D); (B) Except in the case of distributions in liquidation, between an individual and a corporation more than 50 per centum in value of the outstanding stock of which is owned, directly or indirectly, by or for such individual...
863. lappuse - In addition to such stock or securities), or (B) as paid-in surplus or as a contribution to capital, then the basis 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.
818. lappuse - For the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body...
5. lappuse - ... the principal purpose for which such acquisition was made is evasion or avoidance of Federal income tax by securing the benefit of a deduction, credit, or other allowance which such person or corporation would not otherwise enjoy, then the Secretary may disallow such deduction, credit, or other allowance.
661. lappuse - ... attributable to property transferred (in trust or otherwise) in discharge of, a legal obligation which, because of the marital or family relationship, is imposed upon or incurred by such husband under such decree or under a written instrument incident to such divorce or separation...
64. lappuse - An Individual shall be considered as owning the stock owned, directly or Indirectly, by or for his family...
121. lappuse - Amounts received under a life insurance contract paid by reason of the death of the insured, whether in a single sum or otherwise (but if such amounts are held by the insurer under an agreement to pay interest thereon, the interest payments shall be included in gross income); (2) ANNUITIES, ETC.