Reports of the Tax Court of the United States, Volume 32U.S. Government Printing Office, 1960 |
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Halaman 1
... contends in the alternative , should we hold that he is taxable on his proportionate part of Hekor's Supplement P net income for the year 1951 , that nevertheless he would be taxable only on his proportion of Hekor's Supplement P net ...
... contends in the alternative , should we hold that he is taxable on his proportionate part of Hekor's Supplement P net income for the year 1951 , that nevertheless he would be taxable only on his proportion of Hekor's Supplement P net ...
Halaman 17
... contends that for the purposes of section 331 ( a ) ( 2 ) beneficial interest and control over the stock , rather than bare legal title thereto , is determina- tive . Section 331 ( a ) ( 2 ) reads as follows : Hekor had no Supplement P ...
... contends that for the purposes of section 331 ( a ) ( 2 ) beneficial interest and control over the stock , rather than bare legal title thereto , is determina- tive . Section 331 ( a ) ( 2 ) reads as follows : Hekor had no Supplement P ...
Halaman 20
... contends , that fact would not be sufficient justification for us to say that Congress did not intend that section 337 should apply to a taxpayer occupying the situation of petitioner . Cf. Helvering v . Northwest Steel Rolling Mills ...
... contends , that fact would not be sufficient justification for us to say that Congress did not intend that section 337 should apply to a taxpayer occupying the situation of petitioner . Cf. Helvering v . Northwest Steel Rolling Mills ...
Halaman 26
... contends that no carryover would be available for 1943 absent section 722 relief for 1942 , and that , therefore , applica- tion of section 722 to 1942 was what necessarily gave rise to the carryover to 1943 . However , the carryover of ...
... contends that no carryover would be available for 1943 absent section 722 relief for 1942 , and that , therefore , applica- tion of section 722 to 1942 was what necessarily gave rise to the carryover to 1943 . However , the carryover of ...
Halaman 27
... contends that any credit carryover available for that year must be claimed in accordance with the requirements of section 722 and Regulations 112 , section 35.722-5 . This contention is not supported by either the statute or the appli ...
... contends that any credit carryover available for that year must be claimed in accordance with the requirements of section 722 and Regulations 112 , section 35.722-5 . This contention is not supported by either the statute or the appli ...
Edisi yang lain - Lihat semua
Reports of the Tax Court of the United States, Volume 38 United States. Tax Court Tampilan utuh - 1963 |
Reports of the Tax Court of the United States, Volume 23 United States. Tax Court Tampilan utuh - 1956 |
Reports of the Tax Court of the United States, Volume 37 United States. Tax Court Tampilan utuh - 1962 |
Istilah dan frasa umum
16th amendment Adwood agreed agreement amendment amount AOTC application assessment assets bank base period basis capital gain cash cent claimed class B common Commissioner common stock computed constituted construction contract corporation cost Court death decedent's December 31 deduction deficiency depreciation directors distribution dividend Docket Double Oaks equipment excess profits tax exchange expenses Federal filed follows Gratuity Fund gross income Hekor held hereinafter included income tax income tax returns insurance company interest Internal Revenue Code inventory investment issue January June 30 lease liability loan loss ment mortgage net income operation ordinary income paid parties partnership Patenotre payable payment peti petitioner petitioner's preferred stock prior purchase purpose pursuant receipts received rent rental reported respect respondent determined respondent's Schalk selling shareholders shares Sheldon Whitehouse sold statute stipulated stockholders supra tankers taxable taxpayer tion tioner transfer trust United Weatherford
Bagian yang populer
Halaman 414 - gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived...
Halaman 223 - Rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or Is not taking title or In which he has no equity.
Halaman 324 - 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...
Halaman 219 - ... (b) Sales of realty and casual sales of personalty. — In the case (1) of a casual sale or other casual disposition of personal property (other than 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), for a price exceeding $1,000...
Halaman 789 - All interest paid or accrued within the taxable year on indebtedness, except on indebtedness incurred or continued to purchase or carry obligations or securities (other than obligations of the United States issued after September 24, 1917, and originally subscribed for by the taxpayer) the interest upon which is wholly exempt from taxation under this title...
Halaman 414 - ... 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 ; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each is substantially in proportion to his interest in the property prior to the exchange.
Halaman 99 - The fact that the earnings or profits of a corporation are permitted to accumulate beyond the reasonable needs of the business shall be determinative of the purpose to avoid surtax upon shareholders unless the corporation by the clear preponderance of the evidence shall prove to the contrary.
Halaman 532 - Property Used in the Trade or Business. — (1) Definition of property used in the trade or business. — For the purposes of this subsection, the term "property used in the trade or business...
Halaman 527 - The net income of the estate or trust shall be computed in the same manner and on the same basis as in the case of an individual...
Halaman 470 - Amounts distributed in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock, and amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the stock.