Reports of the United States Tax Court, 63. sējums

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United States Tax Court, 1974

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160. lappuse - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include 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...
262. lappuse - ... (a) General rule. If contributions are paid by an employer to or under a stock bonus, pension, profit-sharing, or annuity plan, or If compensation is paid or accrued on account of any employee under a plan deferring the receipt of such compensation, such contributions or compensation shall not be deductible under section 162 (relating to trade or business expenses...
447. lappuse - ... the principal purpose for which such acquisition was made is evasion or avoidance of Federal income or excess profits tax by securing the benefit of a deduction, credit, or other allowance which such person or corporation would not otherwise enjoy, then such deduction, credit, or other allowance shall not be allowed.
47. lappuse - Trade or business expenses — (a) In general. There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business...
301. lappuse - The remedial character of sanctions imposing additions to a tax has been made clear by this Court in passing upon similar legislation. They are provided primarily as a safeguard for the protection of the revenue and to reimburse the Government for the heavy expense, of investigation and the loss res.ulting from the taxpayer's fraud.
588. lappuse - If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return...
515. lappuse - Expenses for production of income. 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.
30. lappuse - SEC. 381. Carryovers in certain corporate acquisitions — (a) General rule. In the case of the acquisition of assets of a corporation by another corporation — (1) In a distribution to such other corporation to which section 332 (relating to liquidations of subsidiaries) applies, except in a case in which the basis of the assets distributed is determined under section...
430. lappuse - Within the 12-month period beginning on the date of the adoption of such plan...
90. lappuse - If a partner engages in a transaction with a partnership other than in his capacity as a member of such partnership, the transaction shall, except as otherwise provided in this section, be considered as occurring between the partnership and one who is not a partner.

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