Reports of the United States Tax Court, 55. sējumsThe Court, 1970 |
No grāmatas satura
1.–5. rezultāts no 100.
31. lappuse
... percent interest in R & C. The remain- ing 50 percent of R & C was owned by members of the Robilio family . Under the terms of his will Thomas authorized his executor to sell his interest in R & C : on whatever terms and at whatever ...
... percent interest in R & C. The remain- ing 50 percent of R & C was owned by members of the Robilio family . Under the terms of his will Thomas authorized his executor to sell his interest in R & C : on whatever terms and at whatever ...
33. lappuse
... percent interest in R & C. The remain- ing 50 percent of R & C was owned by members of the Robilio family . Under the terms of his will Thomas authorized his executor to sell his interest in R & C : on whatever terms and at whatever ...
... percent interest in R & C. The remain- ing 50 percent of R & C was owned by members of the Robilio family . Under the terms of his will Thomas authorized his executor to sell his interest in R & C : on whatever terms and at whatever ...
37. lappuse
... percent interest in the same partnership . The remaining 50 percent of R & C was owned by the Robilio family . Sec . 162 ( a ) , I.R.C. 1954 , must be construed in pari materia with sec . 212. If the deduc- tion is not allowed under sec ...
... percent interest in the same partnership . The remaining 50 percent of R & C was owned by the Robilio family . Sec . 162 ( a ) , I.R.C. 1954 , must be construed in pari materia with sec . 212. If the deduc- tion is not allowed under sec ...
38. lappuse
... percent interest in R & C after giving Zadie an option to purchase his interest or to sell her own interest in the partnership . Zadie chose not to purchase this addi- tional interest in R & C and Thomas ' estate sold it to the Robilios ...
... percent interest in R & C after giving Zadie an option to purchase his interest or to sell her own interest in the partnership . Zadie chose not to purchase this addi- tional interest in R & C and Thomas ' estate sold it to the Robilios ...
40. lappuse
... percent interest in R & C. The complaint filed on behalf of Martha with the District Court sought an order of reconveyance . It is manifest that this would require a conveyance of title to the interest . Not only was " the origin of the ...
... percent interest in R & C. The complaint filed on behalf of Martha with the District Court sought an order of reconveyance . It is manifest that this would require a conveyance of title to the interest . Not only was " the origin of the ...
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agree allocation amount Ann Coates apply assets bad debt basis beneficiary certificates certiorari community property contract corporation cost decedent decedent's December 31 decision deduction director of internal distribution district director dividend earnings election employee expenditures expenses Federal income tax Fidelity filed follows funds gift gift tax gross income hardboard held Income Tax Regs income tax return incurred interest Internal Revenue Code issue lease liability Liberace liquidation loans loss Mason & Dixon ment notice of deficiency operating opinion ordinary income paid parent parties payments percent peti petition petitioner petitioner's Pintsch prior profit purchase purpose pursuant received regulations reserve respect Respondent determined RESPONDENT Docket respondent's Screen Gems section 162 shareholders shares statutory stipulated subsidiary supra taxable income taxpayer Teragram termination tion tioner trade or business transaction transferred trust instrument United voting trust York University
Populāri fragmenti
214. lappuse - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
594. lappuse - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses...
52. lappuse - BASIS. (a) DEALERS IN PERSONAL PROPERTY. — Under regulations prescribed by the Commissioner with the approval of the Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the gross profit realized or to be realized when payment is completed, bears to the total contract price.
502. 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...
148. lappuse - Generally, such relationship exists when the person for whom services are performed has the right to control and direct the individual who performs the services, not only as to the result to be accomplished by the work but also as to the details and means by which that result is accomplished ; that is, an employee is subject to the will and control of the employer not only as to what shall be done but how it shall be done.
241. lappuse - ... 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.
594. lappuse - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
447. lappuse - 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...
35. lappuse - In the case of an Individual, there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year — (1) For the production or collection of Income; (2) For the management, conservation, or maintenance of property held for the production of Income; or (3) In connection with the determination, collection, or refund of any tax.
648. lappuse - Commissioner and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.