Reports of the Tax Court of the United States, Volume 31U.S. Government Printing Office, 1959 - Law reports, digests, etc |
Other editions - View all
Common terms and phrases
acquired additions to tax agreed agreement allowed amount assets average base period Bank basis beneficiary bonds Bowlin calendar capital cash cent claimed coal Company computed construction contract corporation cost Court decedent decedent's December 31 decree deduction deficiency Docket Duval County earnings ended June 30 entitled estate tax excess profits tax expenditures expenses filed FINDINGS OF FACT fiscal year ended follows gift tax gross income held hereinafter Hotel Lincoln income tax return interest Internal Revenue Code issue January January 31 June 30 lease liability loan loss marital deduction ment mortgage operation ordinary income paid parties partnership payments period net income peti petitioner petitioner's prior purchase purposes real estate receipts received record reported respect Respondent determined respondent's section 722 selling shares sold stipulated supra taxable taxpayer tion tioner transaction trust instrument United wife Wilmington
Popular passages
Page 345 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include — "(A) 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...
Page 173 - ... if under the trust instrument it is impossible, at any time prior to the satisfaction of all liabilities with respect to employees and their beneficiaries under the trust, for any part of the corpus or income to be (within the taxable year or thereafter) used for, or diverted to, purposes other than for the exclusive benefit of his employees or their beneficiaries...
Page 468 - If a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income which he is required to return, even though it may still be claimed that he is not entitled to retain the money, and even though he may still be adjudged liable to restore its equivalent.
Page 351 - INCOME.] [In computing net income there shall be allowed as deductions:] (e) Losses by Individuals.— In the case of an individual, losses sustained during the taxable year and not compensated for by insurance or otherwise — (1) if incurred in trade or business; or (2) if incurred in any transaction entered into for profit, though not connected with the trade or business...
Page 439 - ... 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.
Page 217 - The amount of all such items shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under methods of accounting permitted under subdivision (b) of section 212, any such amounts are to be properly accounted for as of a different period...
Page 734 - 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...
Page 648 - 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 (as defined in section 368 (c) ) of the corporation. For purposes of this section, stock or securities issued for services shall not be considered as issued in return for property.
Page 863 - No interest is good unless it must vest, if at all, not later than twenty-one years after some life in being at the creation of the interest.
Page 29 - All interest paid or accrued within the taxable year on indebtedness, except on indebtedness incurred or continued to purchase or carry obligations or securities (other than obligations of the United States issued after September 24, 1917, and originally subscribed for by the taxpayer) the interest upon which is wholly exempt from taxation under this title...