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" 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... "
Reports of the Tax Court of the United States - Página 28
por United States. Tax Court - 1974
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Technical Amendments to Internal Revenue Code: Hearings Before a ...

United States. Congress. House. Committee on Ways and Means, United States. Congress. House. Committee on Ways and Means. Subcommittee on Internal Revenue Taxation - 1956 - 522 páginas
...property "with respect to which the amount realized on a sale or exchange by the partnership would be considered as an amount realized from the sale...exchange of property other than a capital asset." This language was designed with the thought of preventing the contribution to a partnership of section...
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Revised Report on Partners and Partnerships Received by the Subcommittee on ...

United States. Congress. House. Committee on Ways and Means - 1957 - 60 páginas
...percent of the capital interests or profits interests, any gain recognized shall be considered as gain from the sale or exchange of property other than a capital asset. For purposes of this paragraph a person shall be considered as owning any interest owned by his spouse,...
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Suggested Rearrangement of Partner and Partnership Provisions of ..., Volume 36

United States. Congress. House. Committee on Ways and Means - 1958 - 44 páginas
...inventory items. Sec. 751 (a) SEC. 749. SALE OF EXCHANGE OF UNREALIZED RECEIVABLES OR INVENTORY ITEMS. The amount of any money, or the fair market value...or exchange of property other than a capital asset. See. 751 (b) and SEC 750 DISTRIBUTIONS WITH RESPECT TO UNREALIZED RECEIVABLES OR INVENTORY ITEMS. (a)...
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General Revenue Revision: Hearings Before the Committee on Ways and Means ...

United States. Congress. House. Committee on Ways and Means - 1958 - 1176 páginas
...property "with respect to which the amount realized on a sale or exchange by the partnership would be considered as an amount realized from the sale...exchange of property other than a capital asset." This language was designed with the thought of preventing the contribution to a partnership of section...
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General Revenue Revision: Hearings Before the Committee on Ways and Means ...

United States. Congress. House. Committee on Ways and Means - 1958 - 1170 páginas
...property "with aspect to which the amount realized on a sale or exchange by the partnership would e considered as an amount realized from the sale or exchange of property other than capital asset." This language was designed with the thought of preventing the mtribution to a partnership...
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Advisory Group Recommendations on Subchapters C, J, and K of the Internal ...

United States. Congress. House. Committee on Ways and Means - 1959 - 1064 páginas
...amount of such gain attributable to section 751 assets of the partnership shall be considered as gain from the sale or exchange of property other than a capital asset. The amount of gain attributable to section 751 assets of the partnership shall be the amount of the...
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Advisory Group Recommendations on Subchapters C, J, and K of the Internal ...

United States. Congress. House. Committee on Ways and Means - 1959 - 1064 páginas
...amount of such gain attributable to section 751 assets of the partnership shall be considered as gain from the sale or exchange of property other than a capital asset. The amount of gain attributable to section 751 assets of the partnership shall be the amount of the...
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Trust and Partnership Income Tax Revision Act of 1960: Hearings Before the ...

United States. Congress. Senate. Committee on Finance - 1960 - 226 páginas
...property in the hands of such distributee partner) of section 751 assets shall be considered gain or loss from the sale or exchange of property other than a capital asset. "SEC. 736. HOLDING PERIOD FOR DISTRIBUTED PROPERTY. "In determining the period for which a partner...
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Internal Revenue Code of 1954, as Amended and in Force on January 3, 1961

United States, United States. Congress. Joint Committee on Internal Revenue Taxation - 1961 - 1208 páginas
...751. UNREALIZED RECEIVABLES AND INVENTORY ITEMS. (a) SALE OK EXCHANGE OF INTEREST IN PARTNERSHIP. — grain bin, or gram elevator, or anv similar structure...which crib, bin, elevator, or structure is intended (b) CERTAIN DISTRIBUTIONS TREATED AS SALES OR EXCHANGES. — (1) GENERAL RULE. — To the extent a...
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Code of Federal Regulations: Containing a Codification of Documents of ...

1961 - 566 páginas
...751. Unrealized receivables and inventory items — (a) Sale or exchange of interest in partnership. The amount of any money, or the fair market value...or exchange of property other than a capital asset. (b) Certain distributions treated as sales or exchanges — (1) General rule. To the extent a partner...
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