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" Here we have the essential matter: Not a gain accruing to capital, not a growth or increment of value in the investment, but a gain, a profit, something of exchangeable value proceeding from the property, severed from the capital however invested or employed,... "
Cases Decided in the United States Court of Claims ... with Report of ... - Page 513
by United States. Court of Claims, Audrey Bernhardt - 1958
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Computer Science and Law

Brian Niblett - Computers - 1980 - 264 pages
...not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value, proceeding from the property, severed from...from property. Nothing else answers the description. 252 US 189, 207 (1920) The insistent italics of this quotation are particularly revealing, since they...
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Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ...

Expatriation - 1995 - 386 pages
...not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...from property. Nothing else answers the description. (252 US at 206-07). 131 In Bruun, the Court upheld the imposition of tax on a lessor who reclaimed...
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Taxation of Individuals who Renounce Their U.S. Citizenship: Hearing Before ...

United States. Congress. Senate. Committee on Finance - Business & Economics - 1996 - 176 pages
...US 151 22 150 increment of value in the investment, but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...from property Nothing else answers the description " [Italics omitted.] This opinion will demonstrate that the foregoing definition is not an obstacle...
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Taxation of Individuals who Renounce Their U.S. Citizenship: Hearing Before ...

United States. Congress. Senate. Committee on Finance - Business & Economics - 1995 - 166 pages
...US 151. 22 150 increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...recipient (the taxpayer) for his separate use, benefit and disposal.—that is income derived from property Nothing else answers the description." [Italics omitted...
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Taxation of Individuals who Renounce Their U.S. Citizenship: Hearing Before ...

United States. Congress. Senate. Committee on Finance - Business & Economics - 1996 - 164 pages
...US 151. 22 L_ increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...recipient (the taxpayer) for his separate use, benefit and disposal;—that is income derived from property Nothing else answers the description " [Italics omitted.]...
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A New Jersey Anthology

Maxine N. Lurie - History - 2010 - 520 pages
...not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...taxpayer) for his separate use, benefit and disposal." Id. at 207. 213. Id. at 199. 214. See Revenue Act of 1916, ch. 463, §2(a), 39 Stat. 756, 757 (current...
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President's 1963 Tax Message: Hearings Before the Committee on Ways and ...

United States. Congress. House. Committee on Ways and Means - Presidents - 1963 - 1342 pages
...not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...property. Nothing else answers the description." (The italic was italics in the original.) Judge Learned Hand, in his concurring opinion in Boxcers v. Taft,...
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Treasury Decisions Under Internal Revenue Laws of the United States, Volume 29

United States. Internal Revenue Service - Taxation - 1928 - 406 pages
...not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...from property. Nothing else answers the description. It may be suggested, though it is not necessary as a basis for decision, that under the reasoning of...
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Opinions of the Attorney General of Puerto Rico, Volume 11

Puerto Rico. Office of the Attorney General - 1922 - 420 pages
...públicos, etc. ... o de ganancias, utilidades o ingresos, cualquiera que sea su índole o procedencia." recipient (the taxpayer) for his separate use, benefit...and disposal; that is income derived from property. Section 11 reads as follows: "That for the purpose of computing the normal tax only, the following...
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Reports of the Tax Court of the United States, Volume 18

United States. Tax Court - Law reports, digests, etc - 1953 - 1374 pages
...something of exchangeable value, proceeding from property, severed from the capital however invested, and coming in, being derived; that is. received or drawn by the recipient for his separate use, benefit and •SEC. 118. DISTRIBUTIONS BY CORPORATIONS. (a) DBFIKITION o» DIVIDEND....
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