Reports of the United States Tax Court, Volume 58United States Tax Court, 1972 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
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affd agree agreement alimony allocation amended American Jewish Committee amount annuity applicable assets basis beneficiary Bermuda trusts capital gain cash certiorari claims Commissioner contends contract corporation Court death decedent decedent's December 31 decision deduction distribution dividend earnings and profits employee entitled estate tax exclusionary rule facts Federal income tax Fehrs filed follows funds gift tax Golconda gross estate gross income held hereinafter included Income Tax Regs income tax return installment interest Internal Revenue Code Internal Revenue Service investment issue lease loan ment opinion option ordinary income paid parties partnership patents payable payments percent period peti petitioner petitioner's preferred stock prior purchase purposes pursuant received redemption referred rental respect Respondent determined RESPONDENT Docket respondent's royalties rule Schmeer section 482 settlor shareholders shares stipulated supra Tacoma Mall taxable income taxpayer tion tioner transaction transfer United wife
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Halaman 323 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include 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...
Halaman 23 - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Halaman 462 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.
Halaman 326 - 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...
Halaman 132 - ... (9) in the case of a plan which provides contributions or benefits for employees some or all of whom are employees within the meaning of...
Halaman 541 - There shall be allowed as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear (including a reasonable allowance for obsolescence) — ( 1 ) Of property used In the trade or business, or (2) Of property held for the production of Income.
Halaman 171 - If the legatee, devisee, donee, or trustee is empowered to divert the property or fund, in whole or in part, to a use or purpose which would have rendered it, to the extent that it is subject to such power, not deductible had it been directly so bequeathed, devised, or given by the decedent, the deduction will be limited to that portion, if any, of the property or fund which is exempt from an exercise of the power.
Halaman 340 - President may authorize, subject to such regulations as he may prescribe, the Department of the Army, the Department of the Navy, the Department of the Air Force, the Department of Commerce...
Halaman 377 - The allowance for depletion under section 23 (m) shall be, in the case of coal mines, 5 per centum, in the case of metal mines and fluorspar mines, 15 per centum, and, in the case of sulfur mines or deposits, 23 per centum, of the gross income from the property during the taxable year, excluding from such gross income an amount equal to any rents or royalties paid or incurred by the taxpayer in respect of the property.
Halaman 233 - If any part of any deficiency is due to negligence, or intentional disregard of rules and regulations but without intent to defraud, 5 per centum of the total amount of the deficiency (in addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency, except that the provisions of section 272 (i).