Reports of the Tax Court of the United States, Volume 27U.S. Government Printing Office, 1957 - Law reports, digests, etc |
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Common terms and phrases
additional agreement amended amount application assets average base period basis capital gain carryback cash cent certiorari claim COMMISSIONER OF INTERNAL Company computed constructive average base contends contract corporation cost Cowen decedent decedent's December 31 decision deduction deficiency disallowed distribution Docket earnings entitled excess profits credit excess profits tax expenses filed FINDINGS OF FACT fiscal follows gift tax gross income held hereinafter income tax income tax return interest Internal Revenue Code issue January joint return Kyron lease manufacture marital deduction ment Merkra October 31 operation paid parties partners partnership payment period net income peti petitioner petitioner's prior production profits net income purchase purposes received respect respondent determined respondent's section 23 settlor shares Skarda South Bend Stanback statute stipulated stockholders supra tax return taxable taxpayer thereof tion tioner trade or business transfer trust trust instrument United wife
Popular passages
Page 599 - The net income shall be computed upon the basis of the taxpayer's annual accounting period (fiscal year or calendar year, as the case may be) in accordance with the method of accounting regularly employed in keeping the books of such taxpayer ; but if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income...
Page 847 - partnership" includes a syndicate, group, pool, joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title, a trust or estate or a corporation; and the term "partner" includes a member in such a syndicate, group, pool, joint venture, or organization.
Page 34 - 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 of the corporation...
Page 306 - 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 894 - If property (as a result of its 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...
Page 415 - 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...
Page 685 - ... of such corporation in complete cancellation or redemption of all its stock shall be considered an adoption of a plan of liquidation, even though no time for the completion of the transfer of the property is specified in such resolution...
Page 34 - In addition to such stock or securities), or (B) as paid-in surplus or as a contribution to capital, then the basis shall be the same as It would be In the hands of the transferor, Increased In the amount of gain or decreased In the amount of loss recognized to the transferor upon such transfer under the law applicable to the year In which the transfer was made.
Page 677 - ... 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 156 - VII of this subchapter) which are attributable to a trade or business carried on by the taxpayer, if such trade or business does not consist of the performance of services by the taxpayer as an employee.