Reports of the Tax Court of the United States, Volume 38U.S. Government Printing Office, 1963 - Law reports, digests, etc |
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acquired addition adjustments agreed agreement allowed amended applicable assets basis capital gain cash certiorari City of Gunnison claimed collateral estoppel computed contract corporation cost Court death decedent decedent's December 31 decision deduction depreciation distribution district director dividend Docket earnings employees entitled equipment escrow expenses fair market value Federal income tax filed fiscal follows gift Grand Bahama gross income held hereinafter included income tax return interest Internal Revenue Code involved issue January Jerseymaid June June 30 Knights of Columbus lease Lexington Herald-Leader liability liquidation ment mortgage October 31 ordinary income paid parties partner partnership payable payments percent period peti petitioner petitioner's Pomona College principal prior profits purchase purpose pursuant real estate respect Respondent determined respondent's September 30 settlor shareholders shares sold Speedway statute stipulated stockholders Stoll supra taxable income taxpayer Thorson tion tioner transfer Trust Company United wife
Popular passages
Page 478 - ... traveling expenses (including the entire amount expended for meals and lodging) while away from home in the pursuit of a trade or business...
Page 310 - Upon the adjudication of bankruptcy of any taxpayer in any bankruptcy proceeding or the appointment of a receiver for any taxpayer in any receivership proceeding before any court of the United States or of any State or Territory or of the District of Columbia, any deficiency (together with all interest, additional amounts, or additions to the tax provided for by law...
Page 338 - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses...
Page 705 - In the case of a false or fraudulent return with intent to evade tax or of a failure to file a return the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time.
Page 92 - If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 per centum of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 5 years after the return was filed.
Page 525 - Any transfer of a material part of his property in the nature of a final disposition or distribution thereof, made by the decedent within two years prior to his death without such consideration, shall, unless shown to the contrary, be deemed to have been made in contemplation of death within the meaning of this title.
Page 705 - If any part of any deficiency is due to negligence, or intentional disregard of rules and regulations but without intent to defraud. 5 per centum of the total amount of the deficiency (In addition to such deficiency) shall be assessed, collected, and paid in the same manner as if it were a deficiency, except that the provisions of section 571, relating to interest on deficiencies, shall not be applicable.
Page 908 - 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 7 - 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 11 - There shall be allowed as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear (including a reasonable allowance for obsolescence) — ( 1 ) Of property used In the trade or business, or (2) Of property held for the production of Income.