Reports of the Tax Court of the United States, Volume 61U.S. Government Printing Office, 1974 |
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Página 25
United States. Tax Court. tion that a reversionary interest , standing by itself , is a disqualifying equity in the property , as the respondent contends in the instant case . Because Chace , which was affirmed by the Fifth Cir- cuit ...
United States. Tax Court. tion that a reversionary interest , standing by itself , is a disqualifying equity in the property , as the respondent contends in the instant case . Because Chace , which was affirmed by the Fifth Cir- cuit ...
Página 39
... Court in N. F. Testor , 40 T.C. 273 ( 1963 ) , affd . 327 F.2d 788 ( C.A. 7 , 1964 ) , and Peter Raich , 46 T.C. 604 ( 1966 ) . That view was rejected by the U.S. Court of Appeals for the Second Circuit in Bongiovanni v . Commissioner ...
... Court in N. F. Testor , 40 T.C. 273 ( 1963 ) , affd . 327 F.2d 788 ( C.A. 7 , 1964 ) , and Peter Raich , 46 T.C. 604 ( 1966 ) . That view was rejected by the U.S. Court of Appeals for the Second Circuit in Bongiovanni v . Commissioner ...
Página 47
United States. Tax Court. 楼( 44 ) LIBERO P. BALDARELLI 47 Baldarelli , Shaffer , and Brenner were parties to a total of 11 franchise agreements with H & R Block , Inc. , all with respect to operations in California . This sales ...
United States. Tax Court. 楼( 44 ) LIBERO P. BALDARELLI 47 Baldarelli , Shaffer , and Brenner were parties to a total of 11 franchise agreements with H & R Block , Inc. , all with respect to operations in California . This sales ...
Página 60
... Court , where there did not appear to be any specific statutory provision comparable to art . 1325 , and where there were highly unusual circumstances involving the laws of at least three coun- tries or jurisdictions . In any event , in ...
... Court , where there did not appear to be any specific statutory provision comparable to art . 1325 , and where there were highly unusual circumstances involving the laws of at least three coun- tries or jurisdictions . In any event , in ...
Página 66
United States. Tax Court. 66 61 UNITED STATES TAX COURT REPORTS ( 61 ) also Brown - Wheeler Co. , 21 B.T.A. 755 , 757 ( 1930 ) . Even if we assume that the petitioners have met the latter requirement of Enochs , it is clear on the basis ...
United States. Tax Court. 66 61 UNITED STATES TAX COURT REPORTS ( 61 ) also Brown - Wheeler Co. , 21 B.T.A. 755 , 757 ( 1930 ) . Even if we assume that the petitioners have met the latter requirement of Enochs , it is clear on the basis ...
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Palavras e frases frequentes
accounts receivable acquired agreed agreement amount apply assets Bandera County basis Bimini Run Canaveral Groves capital gain cash certiorari common stock contract corporation Court debt decedent decedent's decision deduction depreciation distribution dividend embezzled Eureka exchange fact fair market value Federal income tax filed gross income held Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue Jon-Win Kansas River Kelly Supply lease liability license Litton loan ment notice of deficiency Oak Park Old Nassau Oliver Corporation operating loss ordinary income Otterville paid parties partnership patent payable payments percent period Perma-Line Perma-Line's peti petitioner petitioner's prior purchase purposes pursuant ranch Rapid New York Rapid Puerto Rico received respect Respondent determined RESPONDENT Docket section 38 property shareholders shares statute supra taxable income taxpayer tion tioner trade or business transaction transfer trust United White Company White Motor
Passagens conhecidas
Página 482 - If two or more persons conspire either to commit any offense against the United States or to defraud the United States, or any agency thereof in any manner or for any purpose...
Página 16 - ... rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity...
Página 732 - Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains...
Página 160 - In the case of a series of transactions, the date of the last such transaction) ; and (B) stock of the distributing corporation possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
Página 369 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind...
Página 28 - The amount of any money, or the fair market value of any property, received by a transferor partner in exchange for all or a part of his interest in the partnership attributable to...
Página 344 - The gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis provided in section 1011 for determining gain, and the loss shall be the excess of the adjusted basis provided in such section for determining loss over the amount realized.
Página 700 - If, during the taxable year, the recognized gains upon sales or exchanges of property used in the trade or business, plus the recognized gains from the compulsory or involuntary conversion (as a result of 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) of property used in the trade or business...
Página 421 - ... loss year") shall be carried to the earliest of the taxable years to which (by reason of paragraph (1)) such loss may be carried. The portion of such loss which shall be carried to each of the other taxable years shall be the excess, if any, of the amount of such loss over the sum of the taxable income for each of the prior taxable years to which such loss may be carried.
Página 286 - The power of an administrative officer or board to administer a federal statute and to prescribe rules and regulations to that end is not the power to make law, for no such power can be delegated by Congress, but the power to adopt regulations to carry into effect the will of Congress as expressed by the statute. A regulation which does not do this, but operates to create a rule out of harmony with the statute, is a mere nullity.