Reports of the United States Tax Court, 70. sējumsUnited States Tax Court, 1978 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
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9th Cir acquired affd agreement allocated amended amount annuity apply Arthur Smith assets Atlas Bank basis benefit capital carryback cash claim COMMISSIONER OF INTERNAL community property contract Corp corporation Court decedent decedent's December December 31 decision distribution dividends divorce employee entitled estate tax exempt expenses facts fair market value Federal income tax fees filed franchise gross income Hayden Stone held hereinafter Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service issue KBSI liability loan loss Malag marital deduction notice of deficiency operating organization paid parties partnership payable payments percent period petition petitioner petitioner's players prior proceeds profits purchase purposes pursuant qualify received regulations reorganization Rept respect Respondent determined RESPONDENT Docket respondent's Rule shareholders shares statutory stipulated supra taxable taxpayer transaction transfer trust trust instrument United Yawata
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583. 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...
174. 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...
4. lappuse - For the production or collection of income; (2) For the management, conservation, or maintenance of property held for the production of income; or (3) ln connection with the determination, collection, or refund of any tax.
416. lappuse - COMPULSORY COUNTERCLAIMS. A pleading shall state as a counterclaim any claim which at the time of serving the pleading the pleader has against any opposing party, if it arises out of the transaction or occurrence that is the subject matter of the opposing party's claim and does not require for its adjudication the presence of third parties of whom the court cannot acquire jurisdiction.
998. lappuse - A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
1030. lappuse - ... means wages, salaries, or professional fees, and other amounts received as compensation for personal services actually rendered, but does not include that part of the compensation derived by the taxpayer for personal services rendered by him to a corporation which represents a distribution of earnings or profits rather than a reasonable allowance as compensation for the personal services actually rendered.
32. lappuse - ... (D) A transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders immediately before the transfer), or any combination thereof, is in control of the corporation to which the assets are transferred; but only if, in pursuance of the plan, stock or securities of the corporation to which the assets are transferred are distributed in a transaction which...
80. lappuse - While the question of dependency may involve principles of law, the fact remains that dependency is a question of fact to be determined from all the circumstances of the case and the burden of proving it rests upon him who claims it.
105. lappuse - The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same...
899. lappuse - ... taxes assessed against local benefits of a kind tending to increase the value of the property assessed...