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.
265. lappuse
... partnership possessed since it was able to exchange them for a valuable consideration . [ Citing cases . ] That answers the only question presented here . So , we conclude that these particular patents and inventions perfected and ...
... partnership possessed since it was able to exchange them for a valuable consideration . [ Citing cases . ] That answers the only question presented here . So , we conclude that these particular patents and inventions perfected and ...
270. lappuse
... partnership is the purchase , manu- facturing and sale of chemicals and synthetic products and the doing of all things necessary and incident thereto . ARTICLE 3. The said George J. Chertoff shall contribute to the capital of said ...
... partnership is the purchase , manu- facturing and sale of chemicals and synthetic products and the doing of all things necessary and incident thereto . ARTICLE 3. The said George J. Chertoff shall contribute to the capital of said ...
271. lappuse
... partnership but for purposes of this agreement , the contribution from the two trusts of each child totalling $ 10,000.00 shall be deemed one share , a ( one - fifth th interest ) [ sic ] in the partnership , that is , the partnership ...
... partnership but for purposes of this agreement , the contribution from the two trusts of each child totalling $ 10,000.00 shall be deemed one share , a ( one - fifth th interest ) [ sic ] in the partnership , that is , the partnership ...
273. lappuse
... partnership show withdrawals only for taxes , insurance , and bond purchases . The petitioners have treated all the trusts as valid and subsisting trusts . The partnership return of income for 1941 showed total sales in the amount of ...
... partnership show withdrawals only for taxes , insurance , and bond purchases . The petitioners have treated all the trusts as valid and subsisting trusts . The partnership return of income for 1941 showed total sales in the amount of ...
274. lappuse
... partnership aspects of the case . Respondent contends that the petitioners are taxable on the income of these trusts under section 22 ( a ) , Internal Revenue Code , as construed in Helvering v . Clifford , 309 U. S. 331 , and that in ...
... partnership aspects of the case . Respondent contends that the petitioners are taxable on the income of these trusts under section 22 ( a ) , Internal Revenue Code , as construed in Helvering v . Clifford , 309 U. S. 331 , and that in ...
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Bieži izmantoti vārdi un frāzes
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...