Reports of the Tax Court of the United States, Volume 20

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U.S. Government Printing Office, 1954

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Página 226 - partnership" includes a syndicate, group, pool, joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title, a trust or estate or a corporation; and the term "partner" includes a member in such a syndicate, group, pool, joint venture, or organization.
Página 505 - 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...
Página 175 - ... 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.
Página 315 - For the purpose of this rule a dealer in securities is a merchant of securities, whether an individual, partnership, or corporation, with an established place of business, regularly engaged in the purchase of securities and their resale to customers...
Página 794 - ... (2) if under the trust instrument it is impossible, at any time prior to the satisfaction of all liabilities with respect to employees...
Página 67 - Deductions otherwise allowed by law not attributable to the operation of a trade or business regularly carried on by the taxpayer...
Página 129 - No gain or loss shall be recognized if property is transferred to a corporation by 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...
Página 637 - In addition to such stock or securities), or (B) as paid-in surplus or as a contribution to capital, 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 such transfer under the law applicable to the year In which the transfer was made.
Página 158 - America in determining the income and excess-profits taxes, including all surtaxes, of its citizens or residents or corporations, may include in the basis upon which such taxes are imposed all items of income taxable under the revenue laws of the United States of America as though this Convention had not come into effect.
Página 422 - Where property is transferred for less than an adequate and full consideration in money or money's worth, then the amount by which the value of the property exceeded the value of the consideration shall be deemed a gift, and shall be included in computing the amount of gifts made during the calendar year.

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