Reports of the United States Tax Court, 69. sējumsU.S. Government Printing Office, 1978 |
No grāmatas satura
1.–5. rezultāts no 100.
1. lappuse
... holding company , was liquidated and all of its assets were transferred to its shareholders . At liquidation the corporation's liabilities included " qualified indebtedness " as defined in sec . 545 ( c ) ( 3 ) . Sec . 545 ( c ) ( 1 ) ...
... holding company , was liquidated and all of its assets were transferred to its shareholders . At liquidation the corporation's liabilities included " qualified indebtedness " as defined in sec . 545 ( c ) ( 3 ) . Sec . 545 ( c ) ( 1 ) ...
2. lappuse
... holding company within the meaning of section 545 ( a ) for its final year of activity ( its fiscal year ended on October 31 , 1973 ) , that it had undistributed personal holding company income for that year of $ 7,643.52 , and that it ...
... holding company within the meaning of section 545 ( a ) for its final year of activity ( its fiscal year ended on October 31 , 1973 ) , that it had undistributed personal holding company income for that year of $ 7,643.52 , and that it ...
3. lappuse
... holding company income . Since the $ 15,491.45 exceeded Claire's taxable income for the taxable year in issue , if petitioners are correct there would be no undistribut- ed personal holding company income , hence no deficiency . Section ...
... holding company income . Since the $ 15,491.45 exceeded Claire's taxable income for the taxable year in issue , if petitioners are correct there would be no undistribut- ed personal holding company income , hence no deficiency . Section ...
4. lappuse
... holding company to pay the debt ( or set aside funds therefor ) . It nowhere authorizes us to treat such a debt as paid merely because the corporate assets are distributed to an assuming transferee . We have considerable difficulty with ...
... holding company to pay the debt ( or set aside funds therefor ) . It nowhere authorizes us to treat such a debt as paid merely because the corporate assets are distributed to an assuming transferee . We have considerable difficulty with ...
12. lappuse
... holding is found in Peoples Trust Co. of Bergen County v . United States , 412 F.2d 1156 ( 3d Cir . 1969 ) , wherein taxpayer similarly argued that the term " required " means " needs " and that the power to consume is limited by a duty ...
... holding is found in Peoples Trust Co. of Bergen County v . United States , 412 F.2d 1156 ( 3d Cir . 1969 ) , wherein taxpayer similarly argued that the term " required " means " needs " and that the power to consume is limited by a duty ...
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5th Cir addition to tax adjusted basis affd agreement allocation amended amount application assets Bank bankruptcy beneficiary benefit capital cash CBCC charitable claimed COMMISSIONER OF INTERNAL community property contract contributions Corp corporation death debt decedent decedent's December 31 decision deduction distributions employees ended September 30 entitled estate tax exempt expenses facts fair market value Federal income tax Feroleto filed funds gift tax gross estate gross income held Holgersons included Income Tax Regs income tax return inheritance tax interest Internal Revenue Code Internal Revenue Service issue liability loan notice of deficiency operating loss opinion oyster paid parties partnership payment percent petition petitioner petitioner's prior purchase purposes pursuant qualify received respect Respondent determined RESPONDENT Docket respondent's securities September 30 shareholders shares statutory stipulated supra taxable income taxable year ended taxpayer transaction transfer United unpaid losses
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xiv. lappuse - O divine Master, grant that I may not so much seek to be consoled as to console; to be understood as to understand; to be loved as to love; for it is in giving that we receive, it is in pardoning that we are pardoned, and it is in dying that we are born to eternal life.
491. lappuse - ... organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or...
306. lappuse - All laws should receive a sensible construction. General terms should be so limited in their application as not to lead to injustice, oppression, or an absurd consequence. It will always, therefore, be presumed that the legislature intended exceptions to its language, which would avoid results of this character. The reason of the law in such cases should prevail over its letter.
663. lappuse - In the case of a series of transactions, the date of the last such transaction) ; and (B) stock of the distributing corporation possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
307. lappuse - It is a familiar rule that a thing may be within the letter of the statute and yet not within the statute, because not within its spirit, nor within the intention of its makers.
252. lappuse - Joint names and payable to either or the survivor, except such part thereof as may be shown to have originally belonged to such other person and never to have been received or acquired by the latter from the decedent for less than an adequate and full consideration in money or money's worth...
42. lappuse - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
23. lappuse - Upon the adjudication of bankruptcy of any taxpayer in any bankruptcy proceeding or the appointment of a receiver for any taxpayer in any receivership proceeding before any court of the United States or of any State or Territory or of the District of Columbia, any deficiency (together with all interest, additional amounts, or additions to the tax provided for by law...
515. lappuse - Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subject to substantial limitations or restrictions.
210. 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...