Reports of the Tax Court of the United States, Volume 7U.S. Government Printing Office, 1947 |
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Página 27
... acquired by the Coleman interests , and 49 per cent of the common would be acquired by the bondholders of Detwiler . The committee was to cause fore- closure under the trust indenture , bid in the Detwiler properties at the foreclosure ...
... acquired by the Coleman interests , and 49 per cent of the common would be acquired by the bondholders of Detwiler . The committee was to cause fore- closure under the trust indenture , bid in the Detwiler properties at the foreclosure ...
Página 29
... acquired with the 600 shares of preferred . The 521 shares issued to the bondholders were set up on the books at a value of $ 22,924.25 , and the same value was shown for the total number of shares of common stock outstanding , namely ...
... acquired with the 600 shares of preferred . The 521 shares issued to the bondholders were set up on the books at a value of $ 22,924.25 , and the same value was shown for the total number of shares of common stock outstanding , namely ...
Página 30
... acquired at a bargain price . The cost is meas- ured by the liabilities assumed and the fair market value of the common stock issued therefor , which value is held to be not more than the $ 22,924.25 originally assigned at incorporation ...
... acquired at a bargain price . The cost is meas- ured by the liabilities assumed and the fair market value of the common stock issued therefor , which value is held to be not more than the $ 22,924.25 originally assigned at incorporation ...
Página 31
... acquired in exchange for its common stock . * * * * * * part of We agree that the present transactions come within the definition of a reorganization as that term is defined in section 112 ( g ) ( 1 ) ( B ) of the Revenue Act of 1934 ...
... acquired in exchange for its common stock . * * * * * * part of We agree that the present transactions come within the definition of a reorganization as that term is defined in section 112 ( g ) ( 1 ) ( B ) of the Revenue Act of 1934 ...
Página 32
... acquired by petitioner after December 31 , 1917 , in connection with a reorganization . But an interest or control ... acquired as paid - in surplus or as a contribu- tion to capital . Section 112 ( b ) ( 5 ) deals with transfers to a ...
... acquired by petitioner after December 31 , 1917 , in connection with a reorganization . But an interest or control ... acquired as paid - in surplus or as a contribu- tion to capital . Section 112 ( b ) ( 5 ) deals with transfers to a ...
Índice
42 | |
66 | |
173 | |
198 | |
205 | |
219 | |
226 | |
247 | |
643 | |
700 | |
986 | |
992 | |
1136 | |
1202 | |
1284 | |
1298 | |
255 | |
263 | |
310 | |
321 | |
370 | |
372 | |
510 | |
585 | |
600 | |
1373 | |
1433 | |
1472 | |
1481 | |
1489 | |
1501 | |
1507 | |
1511 | |
Outras edições - Ver tudo
Reports of the Tax Court of the United States, Volume 108 United States. Tax Court Visualização integral - 1997 |
Reports of the Tax Court of the United States, Volume 118 United States. Tax Court Visualização integral - 2002 |
Reports of the Tax Court of the United States, Volume 111 United States. Tax Court Visualização integral - 1998 |
Palavras e frases frequentes
acquired agreement amended amount assets bank basis beneficiary bonds capital cash cent claim Clarksburg Glass COMMISSIONER OF INTERNAL computed contract corporation cost death decedent decedent's December 31 deduction deficiency determined distributed Docket earnings entitled excess profits tax expenses filed FINDINGS OF FACT fiscal year ended follows gift tax gross income Harry and Max held Helvering included income tax income tax return installment interest Internal Revenue Code investment issue January July June 30 lease Lehn & Fink loss manufacturing Memphis Hotel ment mortgage net income operation paid parties partners partnership payment Peabody Hotel peti petitioner petitioner's prior purchase purposes pursuant question received renegotiation reorganization respondent respondent's Revenue Act Rimnik royalty section 23 sell settlor shares Sherover statute stipulated stockholders supra TAX COURT taxable taxpayer thereof tion tioner transfer trust trust instrument UNITED STATES REPORTS
Passagens conhecidas
Página 884 - To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, 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...
Página 478 - ... 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 (1) the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom ; except in case of a bona fide sale for an adequate and full consideration in money or money's...
Página 645 - 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...
Página 20 - 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...
Página 538 - ... (b) There shall be allowed as an additional deduction in computing the net income of the estate or trust the amount of the income of the estate or trust for its taxable year which Is to be distributed currently...
Página 405 - General rule. — (1) Decree of divorce or separate maintenance. — If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance...
Página 413 - Immediately after the transfer an interest or control In such property of 80 per centum or more remained In the same persons or any of them, then the basis shall be the same as It would be In the hands of the transferor, Increased In the amount of gain or decreased In the amount of loss recognized to the transferor upon gueh transfer under the law applicable to the year In which the transfer was made.
Página 492 - reorganization" means (A) a merger or consolidation (including the acquisition by one corporation of at least a majority of the voting stock and at least a majority of the total number of shares of all other classes of stock of another corporation, or substantially all the properties of another corporation...
Página 689 - Intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, in discharge of) a legal obligation which, because of the marital or family relationship, is Imposed on or incurred by the husband under the decree or under a written Instrument Incident to such divorce or separation.
Página 373 - Gains and losses from involuntary conversion and from the sale or exchange of certain 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...