Reports of the Tax Court of the United States, Volume 77U.S. Government Printing Office, 1981 |
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 7 United States. Tax Court Visualização integral - 1947 |
Reports of the Tax Court of the United States, Volume 118 United States. Tax Court Visualização integral - 2002 |
Palavras e frases frequentes
adjusted affd agreement allocable amended amount apartment complex apply Aragon assets Bank basis bonds cash Champion claimed Commissioner computation Congress contends contract corporation costs December 31 declaratory judgment deduction depreciation DISC dividend entitled escrow estate tax exempt expenses fact Federal income tax filed Film funds gross income held hereinafter IDBs Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service inventory investment credit issue Kings Beach liability loan loss ment mortgage notice of deficiency operating opinion ordinary income Orem paid parties partners partnership payments percent petition petitioner petitioner's preferred stock purchase purposes pursuant received redemption referred regulations rental Rept respect respondent's Rockwell Rule salvage value Segura shareholders shares statute subsection supra Tahoe City Tax Court taxable income taxpayer tion trade or business transaction transfer price United value engineering Wobaco Trust
Passagens conhecidas
Página 918 - In the hands of the transferor corporation, and the principal purpose for which such acquisition was made Is evasion or avoidance of Federal Income tax by securing the benefit of a deduction, credit, or other allowance which such person or corporation would not otherwise enjoy, then such deduction, credit, or other allowance shall not be allowed.
Página 656 - medical care" means amounts paid — (A) for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including...
Página 1040 - Secretary or his delegate may 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.
Página 755 - B exceeds the excess of — (1) the sum of (A) the amount shown as the tax by the taxpayer upon his return, if a return was made by the taxpayer and an amount was shown as the tax by the taxpayer thereon, plus (B) the amounts previously assessed (or collected without assessment) as a deficiency, over — (2) the amount of rebates, as defined in subsection (b) (2), made.
Página 745 - No distribution may be made if, after giving it effect: (1) the corporation would not be able to pay its debts as they become due in the usual course of business...
Página 921 - Among the ordinary and necessary expenses paid or incurred in carrying on any trade or business may be included a reasonable allowance for salaries or other compensation for personal services actually rendered. The test of deductibility in the case of compensation payments is whether they are reasonable and are in fact payments purely for services.
Página 961 - ... in value of its outstanding stock is owned, directly or indirectly, by or for not more than five individuals. For the purpose of determining the ownership of stock in a personal holding company...
Página 575 - Deductions otherwise allowed by law not attributable to the operation of a trade or business regularly carried on by the taxpayer...
Página 444 - The excess (if any) of the amount of such contribution over the amount of the reduction under the preceding sentence shall be applied to the reduction (as of the last day of the period specified in the preceding sentence) of the basis of any other property held by the taxpayer. The particular properties to which the reductions required by this paragraph shall be allocated shall be determined under regulations prescribed by the Secretary or his delegate.
Página 229 - Basically, the question in each case is whether the facts alleged, under all the circumstances, show that there is a substantial controversy between parties having adverse legal interests, of sufficient immediacy and reality to warrant the issuance of a declaratory judgment.