The American University Tax Institute Lectures: Papers Presented to the Institutes on Federal Taxes ..., 5. sējumsM. Bender, 1953 |
No grāmatas satura
1.–3. rezultāts no 55.
148. lappuse
... debt to stock was thus 1250 to 1. Again the Tax Court denied the deduction for in- terest , holding that this was " obviously excessive debt structure " within the meaning of the Kelley - Talbot dictum . But the Court also pointed to ...
... debt to stock was thus 1250 to 1. Again the Tax Court denied the deduction for in- terest , holding that this was " obviously excessive debt structure " within the meaning of the Kelley - Talbot dictum . But the Court also pointed to ...
152. lappuse
... debt , and might sometimes be decisive , it held that here such evidence was insufficient to overcome the inference that the loans were at the risk of the business . As the debt - stock ratio in the Kipsborough case was 1000 to 1 , the ...
... debt , and might sometimes be decisive , it held that here such evidence was insufficient to overcome the inference that the loans were at the risk of the business . As the debt - stock ratio in the Kipsborough case was 1000 to 1 , the ...
164. lappuse
... debt structure , and ( 3 ) a combination of the two . The Tax Court has treated the issue essentially as one of proportion , i.e. , of the ratio of debt to stock . In ascertaining that ratio , the Court has not limited itself to a ...
... debt structure , and ( 3 ) a combination of the two . The Tax Court has treated the issue essentially as one of proportion , i.e. , of the ratio of debt to stock . In ascertaining that ratio , the Court has not limited itself to a ...
Saturs
The Washington Headquarters p 5Concen | 7 |
The Organization at the Field Level | 13 |
Day Letters p 19Appellate Division | 20 |
Autortiesības | |
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The American University Tax Institute Lectures: Papers Presented ..., 1. sējums Fragmentu skats - 1946 |
The American University Tax Institute Lectures: Papers Presented ..., 2. sējums Fragmentu skats - 1949 |
The American University Tax Institute Lectures: Papers Presented ..., 3. sējums Fragmentu skats - 1951 |
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accounting affiliated allowed amount Appeals applied assets Assistant authority basis benefits Bureau capital cent claim Code Commissioner common considered consolidated returns contract contributions corporation cost Counsel debt decision deduction determined distribution dividend Division earnings effect employees established excess exemption existing fact factor Federal filed funds gain gross income held holding included income tax individual interest Internal Revenue Internal Revenue Code investment involved issue lease limited liquidation loss ment method operating opinion paid parent partnership payments pension period possible preferred present principle prior problems profits Puerto Rican purchase question rates reasonable received regulations respect result retirement Rico rule securities separate shareholders shares sources stockholders subsidiary supra Tax Court taxable taxpayer term tion transaction transfer treated trust United