Reports of the United States Tax Court, 63. sējumsUnited States Tax Court, 1974 |
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1.–5. rezultāts no 100.
v. lappuse
... distributed to the participants in the proceedings and the invited guests : UNITED STATES TAX COURT The United States Tax Court is a Court of record established under Article I of the Constitution of the United States . It hears and ...
... distributed to the participants in the proceedings and the invited guests : UNITED STATES TAX COURT The United States Tax Court is a Court of record established under Article I of the Constitution of the United States . It hears and ...
28. lappuse
... distributed in complete liquidation of Old Eastern ; ( 2 ) that under section 336 , no gain or loss would be recognized to Old Eastern on the distribution of its property in complete liquidation ; ( 3 ) that the basis of the property of ...
... distributed in complete liquidation of Old Eastern ; ( 2 ) that under section 336 , no gain or loss would be recognized to Old Eastern on the distribution of its property in complete liquidation ; ( 3 ) that the basis of the property of ...
31. lappuse
... distribution or transfer . ( 2 ) For purposes of this section , the date of distribution or transfer shall be the day on which the distribution or transfer is completed ; except that , under regulations prescribed by the Secretary or ...
... distribution or transfer . ( 2 ) For purposes of this section , the date of distribution or transfer shall be the day on which the distribution or transfer is completed ; except that , under regulations prescribed by the Secretary or ...
32. lappuse
... 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 334 ( b ) ( 2 ) ; or ( 2 ) 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 334 ( b ) ( 2 ) ; or ( 2 ) in a ...
34. lappuse
... distribution in complete liquidation within the meaning of section 332 for the purpose of applying section 334 ( b ) ( 2 ) may not be considered a reorganization under section 368 ( a ) ( 1 ) ( A ) for some other unrelated purpose . See ...
... distribution in complete liquidation within the meaning of section 332 for the purpose of applying section 334 ( b ) ( 2 ) may not be considered a reorganization under section 368 ( a ) ( 1 ) ( A ) for some other unrelated purpose . See ...
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agreement amended amount applicable assets basis beneficiary benefit Branjon capital gain cash certiorari claimed Colortype COMMISSIONER OF INTERNAL Computax contract corporation decedent decedent's December 31 decision deduction disallowed distribution employees entitled estate tax exchange expenses fact fair market value Federal income tax filed follows Freeport fund gift tax gross income held Hendry hereinafter Herman Klein Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service issue January lease liability liquidation loans loss notice of deficiency operating ordinary income paid parties partnership payment Pelco percent petition petitioner petitioner's preferred stock prior Pritchett purchase purposes pursuant received record rental reported residence respect Respondent determined RESPONDENT Docket respondent's Rule section 337 shareholders shares sold statutory stipulated stockholders subsection supra TASCO Tax Court taxable taxpayer transaction transfer undivided interests United UNIVAC wagers William du Pont
Populāri fragmenti
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.