Reports of the U.S. Board of Tax Appeals, Volume 31U.S. Government Printing Office, 1935 - Taxation |
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Common terms and phrases
acquired agreed agreement amount assets basis beneficiary Board bonds capital stock cash certificates claimed COMMISSIONER OF INTERNAL common stock computing contends contract corporation cost Court death decedent decedent's December 31 deduction deficiency Delaware corporation depreciation determined distribution Docket entered under Rule entitled estate tax exchange Executors expenses facts fair market value filed funds grantor gross estate gross income held Helvering income tax income tax return interest INTERNAL REVENUE investment issue January Kimberly-Clark Kotex lease lessee liability loss mortgage National Bank net income opinion paid par value parties partnership payment percent peti petitioner petitioner's Phelps Dodge Corporation preferred stock prior proceeding profits Promulgated purchase Railway received respondent respondent's Revenue Act Rule 50 Sand Springs Railway securities shares of stock sold statute stipulated stockholders supra taxable income taxpayer Texas thereof tion tioner transaction transfer trust trust instrument wife
Popular passages
Page 169 - 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 170 - If an exchange would be within the provisions of subsection (b), (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 524 - ... the net income of the estate or trust the amount of the income of the estate or trust for its taxable year which is properly paid or credited during such year to any legatee, heir, or beneficiary...
Page 19 - ... (a) There shall be allowed as a deduction (in lieu of the deduction for charitable, etc., contributions authorized by section 23 (o) ) any part of the gross income, without limitation, which pursuant to the terms of the will or deed creating the trust, is during the taxable year paid or permanently set aside...
Page 370 - ... of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived from any source whatever.
Page 325 - ... 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 334 - To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend? or revoke...
Page 19 - INCOME. The net income of the estate or trust shall be computed in the same manner and on the same basis as in the case of an individual...
Page 552 - 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 498 - The vital principle is that he who, by his language or conduct, leads another to do what he would not otherwise have done, shall not subject such person to loss or injury by disappointing the expectations upon which he acted. Such a change of position is sternly forbidden. It involves fraud and falsehood, and the law abhors both.