Reports of the Tax Court of the United States, Volume 14U.S. Government Printing Office, 1950 - Taxation |
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Common terms and phrases
acquired adjustment agreement amount assets average base period bank basis beneficiary bonds cash cent certificates claimed COMMISSIONER OF INTERNAL common stock computing contract corporation cost Court death decedent decedent's December 28 December 31 deductions deficiency determined disallowed distribution dividends Docket earnings entitled estate tax excess profits credit excess profits tax expenses Fageol filed FINDINGS OF FACT fiscal follows Funk gift tax gross estate gross income Hall-Scott held Helen Saunders Helvering included income tax income tax returns indebtedness interest Internal Revenue Code issue January June 30 ment mortgage operation paid partners partnership patents payable payment period net income peti petitioner petitioner's policies prior proceeding purchase received renegotiation respect respondent respondent's salary section 107 section 722 shares stipulated stockholders supra tax returns taxable taxpayer thereof tion tioner transfer trust trust instrument United wife York
Popular passages
Page 486 - ... gains, profits, and income derived from salaries, wages, or compensation for personal service of whatever kind and in whatever form paid...
Page 259 - 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 165 - 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 6 - 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 285 - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 584 - (a) REQUIREMENTS FOR QUALIFICATION. — A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
Page 111 - ... 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 318 - The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated, except real property situated outside of the United States — (a) DECEDENT'S INTEREST. — To the extent of the interest therein of the decedent at the time of his death ; (c) TRANSFERS IN CONTEMPLATION OF, OR TAKING EFFECT AT DEATH.
Page 173 - ... of such a nature that an extended stay may be necessary for its accomplishment, and to that end the alien makes his home temporarily in the United States, he becomes a resident, though it may be his intention at all times to return to his domicile abroad when the purpose for which he came has been consummated or abandoned.
Page 372 - 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...