Reports of the Tax Court of the United States, Volume 47U.S. Government Printing Office, 1967 |
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Page 15
... included Stanfill , Santelli , and Gold ( hereinafter sometimes called the Dube group ) , and the group began negotiating with the petitioner for the acquisition of his business . After over 6 months of give - and - take negotiations at ...
... included Stanfill , Santelli , and Gold ( hereinafter sometimes called the Dube group ) , and the group began negotiating with the petitioner for the acquisition of his business . After over 6 months of give - and - take negotiations at ...
Page 24
... hand , depreciation totaling $ 8,380 relating to the two buildings leased to Imported was included in expenses deducted in the same return . On December 19 , 1963 , a notice of deficiency 24 ( 11 ) 47 TAX COURT OF UNITED STATES REPORTS.
... hand , depreciation totaling $ 8,380 relating to the two buildings leased to Imported was included in expenses deducted in the same return . On December 19 , 1963 , a notice of deficiency 24 ( 11 ) 47 TAX COURT OF UNITED STATES REPORTS.
Page 29
... included in income by 444. We reject this contention . The 1958 rent payments by Imported to 444 were , presumably and apparently , expended in the same manner for the benefit of petitioner's experimental department in 1958 as they were ...
... included in income by 444. We reject this contention . The 1958 rent payments by Imported to 444 were , presumably and apparently , expended in the same manner for the benefit of petitioner's experimental department in 1958 as they were ...
Page 32
... included in earnings and profits , See also Newark Amusement Corporation , T.C. Memo . 1960-137 , in which we relled on the regulations , followed Alworth and distinguished Drybrough , observing that Drybrough did not specifically ...
... included in earnings and profits , See also Newark Amusement Corporation , T.C. Memo . 1960-137 , in which we relled on the regulations , followed Alworth and distinguished Drybrough , observing that Drybrough did not specifically ...
Page 42
... included in the decedent's gross estate under section 811 ( d ) ( 2 ) of the Internal Revenue Code of 1939 , the predecessor of section 2038 ( a ) ( 1 ) . In so doing , the Court stated ( 346 U.S. at 337 ) : The trust instrument here ...
... included in the decedent's gross estate under section 811 ( d ) ( 2 ) of the Internal Revenue Code of 1939 , the predecessor of section 2038 ( a ) ( 1 ) . In so doing , the Court stated ( 346 U.S. at 337 ) : The trust instrument here ...
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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.