Reports of the Tax Court of the United States, Volume 29U.S. Government Printing Office, 1958 |
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Common terms and phrases
adjustments agreed agreement amended amount application assets average base period bank basis beneficiary carryback cash cent claim Commissioner computed contract corporation cost Court decedent December 31 deduction deficiency Denise disallowed dividends Docket earnings employees excess profits credit excess profits tax filed fiscal year ended follows gift gift tax gross income Hedgecoke held hereinafter included income tax income tax return interest Internal Revenue Code Irma Crall issue J. W. Gordon June June 30 liability ment Mississippi company operating loss ordinary income paid parties partnership patent payable payments period net income peti petitioner petitioner's premiums prior purchase purpose pursuant received record refund renegotiation respect respondent determined respondent's Rondout section 722 sell shares sold Southern Ford statute stipulated stockholders supra taxable taxpayer tion tioner tract index transaction transfer trust trust instrument unused excess profits voting trust
Popular passages
Page 686 - ... 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 ; but in the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each is substantially in proportion to his interest in the property prior to the exchange.
Page 905 - The amounts of the following liabilities shall, except as hereinafter In this section provided, be assessed, collected, and paid In the same manner and subject to the same provisions and limitations...
Page 264 - 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 164 - 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...
Page 142 - Deductions otherwise allowed by law not attributable to the operation of a trade or business regularly carried on by the taxpayer...
Page 824 - A transfer (other than by gift, inheritance, or devise) of property consisting of all substantial rights to a patent, or an undivided interest therein which includes a part of all such rights...
Page 899 - Except as provided in section 276 — (a) GENERAL RULE. — The amount of income taxes imposed by this title shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period.
Page 686 - If an Installment obligation is satisfied at other than its face value or distributed, transmitted, sold, or otherwise disposed of, gain or loss shall result to the extent of the difference between the basis of the obligation and...
Page 506 - Part further covenants and agrees to merchandise such wheat in foreign ports , it being understood and agreed between the Party of the First Part and the Party of the Second Part...
Page 255 - Where before the expiration of the time prescribed in section 275 for the assessment of the tax, both the Commissioner and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.