Reports of the United States Tax Court, 92. sējumsUnited States Tax Court, 1989 |
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1.–5. rezultāts no 100.
3. lappuse
... Corporation ( NDFC ) is a for - profit corporation owned 60 percent by IBN and 40 percent by Bizar . Prior to 1980 , NDFC engaged in various business activities , including the sale of insurance . The Contribution Transaction Bizar ...
... Corporation ( NDFC ) is a for - profit corporation owned 60 percent by IBN and 40 percent by Bizar . Prior to 1980 , NDFC engaged in various business activities , including the sale of insurance . The Contribution Transaction Bizar ...
46. lappuse
... CORPORATION ( OTHER THAN SUBSIDIARY ) -For purposes of sections 302 and 303 , if- ( A ) one or more persons are in control of each of two corporations , and ( B ) in return for property , one of the corporations acquires stock in the ...
... CORPORATION ( OTHER THAN SUBSIDIARY ) -For purposes of sections 302 and 303 , if- ( A ) one or more persons are in control of each of two corporations , and ( B ) in return for property , one of the corporations acquires stock in the ...
47. lappuse
... corporations . Sec . 304 ( a ) ( 1 ) ( A ) . Secondly , one of the corporations , in exchange for property , must have acquired stock in the other corporation from the person so in control . Sec . 304 ( a ) ( 1 ) ( B ) . " Control " is ...
... corporations . Sec . 304 ( a ) ( 1 ) ( A ) . Secondly , one of the corporations , in exchange for property , must have acquired stock in the other corporation from the person so in control . Sec . 304 ( a ) ( 1 ) ( B ) . " Control " is ...
48. lappuse
... corporations acquire stock in the other corporation from the person so in control . In the instant case , Construction , in exchange for property ( debentures ) , acquired the stock of Builders from the Gunthers , the persons in control ...
... corporations acquire stock in the other corporation from the person so in control . In the instant case , Construction , in exchange for property ( debentures ) , acquired the stock of Builders from the Gunthers , the persons in control ...
49. lappuse
... corporation owned by the shareholder ( sec . 302 ( b ) ( 3 ) ) . In applying sec- tion 302 ( b ) , section 304 ( b ) ( 1 ) provides that reference is to be made to each shareholder's ownership of the stock in the issuing corporation ...
... corporation owned by the shareholder ( sec . 302 ( b ) ( 3 ) ) . In applying sec- tion 302 ( b ) , section 304 ( b ) ( 1 ) provides that reference is to be made to each shareholder's ownership of the stock in the issuing corporation ...
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5th Cir addition to tax adjustment affd affg agreement amended American Bar Endowment American Greetings amount apply ARCO stock argues B&L Ireland CBOE claimed Commis Commissioner compensation Congress contributions corporation December 31 deductions Diamond distribution dividend Elco employee entitled estate tax evidence facts Federal income tax filed funds Hallmark held Hydron Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service inventory investment issue Judge Judicial Plan jurisdiction lease lens limited mailed manufacturing market maker master recording molding process motion notice of deficiency NPDC opinion option paid parties partnership payment percent petition petitioner's petitioners premium profit purposes pursuant received respect respondent's retroactive rate credits Robotics royalty Rule shares sioner soft contact lenses spin cast statute statutory supra T.C. Memo Tax Court tax liability tax matters partner taxpayer testimony tion trade or business transactions United valuation
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216. lappuse - ... upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income.
52. 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...
46. lappuse - For purposes of this section, control means the ownership of stock possessing at least 50 percent of the total combined voting power of all classes of stock entitled to vote, or at least 50 percent of the total value of shares of all classes of stock.
678. lappuse - Government in criminal cases, factual findings resulting from an investigation made pursuant to authority granted by law, unless the sources of information or other circumstances indicate lack of trustworthiness.
581. 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...
249. lappuse - At the request of a party the court shall order witnesses excluded so that they cannot hear the testimony of other witnesses, and it may make the order of its own motion. This rule does not authorize exclusion of (1) a party who is a natural person, or (2) an officer or employee of a party which is not a natural person designated as its representative by its attorney, or (3) a person whose presence is shown by a party to be essential to the presentation of the party's cause, or (4) a person authorized...
48. lappuse - Distributions in redemption of stock "(a) General rule. — If a corporation redeems its stock (within the meaning of section 317(b)), and if paragraph (1), (2), (3), or (4) of subsection (b) applies, such redemption shall be treated as a distribution in part or full payment in exchange for the stock. "(b) Redemptions treated as exchanges. — "(1) Redemptions not equivalent to dividends. — Subsection (a) shall apply if the redemption is not essentially equivalent to a dividend.
410. lappuse - Except as otherwise provided in this subtitle, gross income means all income from whatever source derived, including (but not limited to) the following items: (1) Compensation for services, including fees, commissions, and similar items; (2) Gross income derived from business; (3) Gains derived from dealings in property...
49. lappuse - For purposes of this subtitle, the term "dividend" means any distribution of property made by a corporation to its shareholders — (1) out of its earnings and profits accumulated after February 28. 1913, or (2) out of its earnings and profits of the taxable year...
233. lappuse - In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors...