| United States. Internal Revenue Service - 1936 - 604 lapas
...individually or otherwise, and regardless of the place where carried on. (3) The term "controlled" includes any kind of control, direct or indirect,...reality of the control which is decisive, not its form nor the mode of its exercise. A presumption of control arises if income or deductions have been arbitrarily... | |
| United States. Internal Revenue Service - 1936 - 48 lapas
...term "control" includes any kind of control, direct or indirect, whether or not legally enforcible, and however exercisable or exercised. It is the reality of the control which is decisive, not its form nor the mode of its exercise. . CHAPTER II CONDITIONS ON ALLOWANCE OF REFUNDS APPLICABLE TO ALL CLAIMS... | |
| 1939 - 1030 lapas
...individually or otherwise, and regardless of the place where carried on. (3) The term "controlled" includes any kind of control, direct or indirect,...reality of the control which is decisive, not its form nor the mode of its exercise. A presumption of control arises if income or deductions have been arbitrarily... | |
| United States. Tax Court - 1946 - 1804 lapas
...tuxwyer. — (a) -Definitions. — When used in this section — • •**•** (3) The term "controlled" includes any kind of control, direct or indirect,...enforceable, and however exercisable or exercised. It Is the DISNET, /., dissenting: The majority opinion seems to me to be necessarily and essentially based upon... | |
| 1993 - 648 lapas
...organization, trade or business, whether or not subject to any internal revenue tax. (4) Controlled includes any kind of control, direct or indirect,...exercisable or exercised. It is the reality of the control that is decisive, not its form or the mode of its exercise. A presumption of control arises if income... | |
| 1993 - 640 lapas
...organization, trade or business, whether or not subject to any internal revenue tax. (4) Controlled includes any kind of control, direct or indirect,...exercisable or exercised. It is the reality of the control that is decisive, not its form or the mode of its exercise. A presumption of control arises if income... | |
| 2000 - 842 lapas
...purposes of this section, whether undertakings are controlled by the same interests. Рог this purpose, control includes any kind of control, direct or indirect,...however exercisable or exercised. It is the reality of control that is determinative, and not its form or mode of exercise. (2) Presumption — (i) In general.... | |
| 1998 - 646 lapas
...purposes of this section, whether undertakings are controlled by the same interests. For this purpose, control includes any kind of control, direct or indirect,...however exercisable or exercised. It is the reality of control that is determinative, and not its form or mode of exercise. (2) Presumption — (i) In general.... | |
| 1969 - 388 lapas
...individually or otherwise, and regardless of the place where carried on. (3) The term "controlled" includes any kind of control, direct or indirect, whether legally enforceable, and however exerclsable or exercised. It is the reality of the control which is decisive, not its form or the mode... | |
| 1997 - 636 lapas
...interests. For this purpose, control Includes any kind of control, direct or indirect, whether §1.409-4T legally enforceable, and however exercisable or exercised. It is the reality of control that is determinative, and not its form or mode of exercise. (2) Presumption — (i) In general.... | |
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