Reports of the Tax Court of the United States, Volume 47U.S. Government Printing Office, 1967 |
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Page 12
... FACT Some of the facts have been stipulated in writing , and some by oral stipulation at trial . All stipulated facts are incorporated herein by this reference . Petitioner is an individual residing at 1717 Broadway in New York City ...
... FACT Some of the facts have been stipulated in writing , and some by oral stipulation at trial . All stipulated facts are incorporated herein by this reference . Petitioner is an individual residing at 1717 Broadway in New York City ...
Page 18
... Fact herein is for convenience and consistency with the terminology used by the parties at trial and on brief . The use of such term should not be construed to imply a conclusion that the third- floor shop was in fact a " department ...
... Fact herein is for convenience and consistency with the terminology used by the parties at trial and on brief . The use of such term should not be construed to imply a conclusion that the third- floor shop was in fact a " department ...
Page 25
... FACT The so - called experimental department was at all times relevant the personal property of petitioner . During ... facts here are not in dispute . In 1959 Imported paid $ 75,000 to 444 and $ 57,592.57 to the experimental department ...
... FACT The so - called experimental department was at all times relevant the personal property of petitioner . During ... facts here are not in dispute . In 1959 Imported paid $ 75,000 to 444 and $ 57,592.57 to the experimental department ...
Page 27
... fact that Enterprises was to receive rights to patents to be developed in the experimental department . Peti- tioner testified at length concerning his early inventions in the auto- motive field in an effort to establish that his ...
... fact that Enterprises was to receive rights to patents to be developed in the experimental department . Peti- tioner testified at length concerning his early inventions in the auto- motive field in an effort to establish that his ...
Page 28
... fact that 444 saw fit to use the money for the benefit of the petitioner ( through the experimental department ) cannot change the fact that it constituted rental income when received . Palm Beach Aero Corpora- tion , 17 T.C. 1169 ...
... fact that 444 saw fit to use the money for the benefit of the petitioner ( through the experimental department ) cannot change the fact that it constituted rental income when received . Palm Beach Aero Corpora- tion , 17 T.C. 1169 ...
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Common terms and phrases
agree agreement alimony allowed ALPA amount applied assets basis beneficiary benefit Bijou capital gain cash claimed coal Commissioner contract corporation cost Court Crosley death decedent decedent's December 31 deduction director of internal district director dividends divorce Divorce Court Dorsey entitled estate tax expenses Federal income tax filed funds gross estate gross income held hereinafter included income tax return installment interest Internal Revenue Code Internal Revenue Service Iran issue Jisco Krispy Kreme KTTV lease liability loss ment notice of deficiency obligation operating ordinary income paid parties payable payments percent peti petitioner petitioner's Pioneer Plaza Powel Crosley preferred stock prior purchase purpose receipt received respect Respondent determined RESPONDENT Docket respondent's shareholders shares sold sole proprietorship stipulated stockholders Storer Broadcasting supra Tax Regs taxable income taxable year ended taxpayer tion tioner trade or business transfer trust Weigman wife
Popular passages
Page 39 - ... 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...
Page 184 - If property (as a result of its destruction in whole or in part, theft or seizure, or an exercise of the power of requisition or condemnation, or the threat or imminence thereof...
Page 523 - 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...
Page 598 - There shall be allowed as a deduction any loss sustained during the taxable year and not compensated for by insurance or otherwise.
Page 542 - Immediately before the acquisition) ; (C) the acquisition by one corporation. In exchange solely for all or a part of Iti voting stock (or In exchange solely for all or a part of the voting stock of a corporation which is in control of the acquiring corporation...
Page 291 - Is divorced or legally separated from her husband under a decree of divorce or of separate maintenance...
Page 110 - BASIS. (a) DEALERS IN PERSONAL PROPERTY. — Under regulations prescribed by the Commissioner with the approval of the Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the gross profit realized or to be realized when payment is completed, bears to the total contract price.
Page 281 - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
Page 88 - The accumulated earnings tax imposed by section 531 shall apply to every corporation * * * formed or availed of for the purpose of avoiding the income tax with respect to its shareholders or the shareholders of any other corporation, by permitting earnings and profits to accumulate instead of being divided or distributed.
Page 476 - Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate ; 3.