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acquired additional adjusted agreed agreement allowed amount application assets bank base period basis capital cash cent claimed Commissioner commissions Company computed consideration contract corporation cost Court death December Decision deduction deficiency determined distribution dividend earnings effect ended entered entitled evidence excess profits expenses facts filed FINDINGS follows further gain gross income held holding husband included income tax increased interest Internal Revenue Code involved issue January June lease less liability limited loans loss March method month notes obligation October operation opinion paid parties patent payments peti petitioner petitioner's present prior purchase question reason received record referred remaining reported represented respect respondent result sell separate shares sold stipulated stockholders supra tax return taxable taxpayer tion transferred trust United wife
Page 287 - If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend...
Page 616 - All laws should receive a sensible construction. General terms should be so limited in their application as not to lead to injustice, oppression, or an absurd consequence. It will always, therefore, be presumed that the legislature intended exceptions to its language which would avoid results of this character.
Page 497 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...
Page 287 - Amounts distributed in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock, and amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the stock.
Page 308 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 105 - ... the amount actually distributed or made available to any distributee shall be taxable to him in the year in which so distributed or made available to the extent that it exceeds the amounts paid in by him.
Page 56 - ... 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.
Page 734 - In the case of a taxpayer, other than a corporation, only the following percentages of the gain or loss recognized upon the sale or exchange of a capital asset shall be taken Into account In computing net capital gain, net capital loss, and net Income : "100 per centum If the capital asset has been held for not more than 6 months ; "50 per centum if the capital asset has been held for more than 6 months.
Page 837 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include 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 564 - 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.