Reports of the Tax Court of the United States, 6. sējumsU.S. Government Printing Office, 1947 |
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1.–5. rezultāts no 100.
5. lappuse
... opinion the respondent's views should be sustained . Since the opinion of the Supreme Court of the United States in the Vir ginian Hotel case , depreciation must be computed by taking into con- sideration any claims for depreciation ...
... opinion the respondent's views should be sustained . Since the opinion of the Supreme Court of the United States in the Vir ginian Hotel case , depreciation must be computed by taking into con- sideration any claims for depreciation ...
12. lappuse
... opinion the peti- tioners ' views may not be sustained , for there is no contention that the notes carried interest coupons and nothing in the record indicates that they were in registered form , within the meaning of the statutory ...
... opinion the peti- tioners ' views may not be sustained , for there is no contention that the notes carried interest coupons and nothing in the record indicates that they were in registered form , within the meaning of the statutory ...
28. lappuse
... opinion that the sales were completed sales , giving rise to a debt . We are also of the opinion that the debt became worthless during the tax year . The institution of litigation where such action is not justified by any hope of ...
... opinion that the sales were completed sales , giving rise to a debt . We are also of the opinion that the debt became worthless during the tax year . The institution of litigation where such action is not justified by any hope of ...
58. lappuse
... opinion there is no more reason for the respondent to question the deduction of the amounts paid in the taxable years before us than in prior years . The respondent does not contend that the amount of the premium paid in 1940 , together ...
... opinion there is no more reason for the respondent to question the deduction of the amounts paid in the taxable years before us than in prior years . The respondent does not contend that the amount of the premium paid in 1940 , together ...
59. lappuse
... opinion that the evidence does not disprove his determination . I therefore concur in the opinion so far as it dis- allows the deduction from gross income of 1941 of the $ 1,000,000 in question . BLACK , J. , dissenting : I wish to note ...
... opinion that the evidence does not disprove his determination . I therefore concur in the opinion so far as it dis- allows the deduction from gross income of 1941 of the $ 1,000,000 in question . BLACK , J. , dissenting : I wish to note ...
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agreed agreement amount annuity assets assignment bank basis beneficiary benefit bonds capital stock cash certiorari Chertoff claims COMMISSIONER OF INTERNAL computing contends contract corporation corpus cost Court death debentures decedent decedent's December 29 December 31 decision deduction deficiency determined disallowed distribution dividends Docket earnings employees entitled excess profits tax executed expenses filed FINDINGS OF FACT follows fund gift gift tax gross income Haldeman held Helen Alexander Helvering hereinafter Herschbach Howell income tax income tax returns interest Internal Revenue Code investment issue lease liability liquidation ment mortgage net income October 21 operation paid parties partnership payable payment percent period peti petitioner petitioner's preferred stock principal prior purchase purpose received respect respondent Revenue Act section 23 securities shares statute stipulated stockholders supra taxable taxpayer thereof Thurlim tion tioner transfer trust estate trust instrument Turpentine wife
Populāri fragmenti
83. lappuse - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...
287. lappuse - All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually rendered; traveling expenses (including the entire amount expended for meals and lodging) while away from home in the pursuit of a trade or business...
254. lappuse - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include — "(A) 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...
19. lappuse - Income which is to be distributed currently by the fiduciary to the beneficiaries, and income collected by a guardian of an infant which is to be held or distributed as the court may direct...
191. lappuse - ... (B) in a taxable year beginning after December 31, 1935, by a corporation in connection with a reorganization, then the basis shall be the same as it would be in the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year in which the transfer was made.
83. lappuse - Any transfer of a material part of his property in the nature of a final disposition or distribution thereof, made by the decedent within two years prior to his death without such a consideration, shall, unless shown to the contrary, be deemed to have been made in contemplation of death within the meaning of this title...
452. lappuse - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
191. 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...
509. lappuse - ... has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be taxed as a gain from the exchange of property.
451. lappuse - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...