Reports of the Tax Court of the United States, Volume 20U.S. Government Printing Office, 1954 |
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adjustment agreed agreement amended amount assets Ballet Theatre basis beneficiary Brazoria capital gain capital stock cash cent certificates claimed COMMISSIONER OF INTERNAL computed contends contract corporation cost Court decedent decedent's December 31 decision deduction deficiency determined disallowed distribution dividend Docket earnings excess profits credit excess profits tax exchange executed expenses filed FINDINGS OF FACT fiscal year ended follows Grand Rapids gross estate gross income held included income tax income tax return interest Internal Revenue Code issue July July 31 June lease liability loss ment Mokan net income operating ordinary income paid Panhandle Eastern parties partnership payable payment peti petitioner petitioner's policies preferred stock premiums prior purchase pursuant question received refund renegotiation reported respect respondent respondent's Rule 50 section 23 shares sold stipulated stockholders supra taxable taxpayer Texplant tion tioner transaction transfer trust instrument United wife
Popular passages
Page 230 - 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 247 - ... property used in the trade or business, plus the recognized gains from the compulsory or involuntary conversion (as a result of destruction in whole or in part, theft or seizure, or an exercise of the power of requisition or condemnation or the threat or imminence thereof) of property used in the trade or business...
Page 319 - For the purpose of this rule a dealer in securities is a merchant of securities, whether an individual, partnership, or corporation, with an established place of business, regularly engaged in the purchase of securities and their resale to customers...
Page 246 - Involuntary conversion and from the sale or exchange of certain property used In the trade or business — (1) Definition of property used In the trade or business. For the purposes of this subsection, the term "property used in the trade or business...
Page 67 - Deductions otherwise allowed by law not attributable to the operation of a trade or business regularly carried on by the taxpayer...
Page 207 - Where property is transferred for less than an adequate and full consideration in money or money's worth, then the amount by which the value of the property exceeded the value of the consideration shall be deemed a gift, and shall be included in computing the amount of gifts made during the calendar year.
Page 178 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, 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 129 - 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 302 - 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 ; but if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income...
Page 330 - ... (3) In any event the allowance for the compensation paid may not exceed what is reasonable under all the circumstances. It is, in general, just to assume that reasonable and true compensation is only such amount as would ordinarily be paid for like services by like enterprises under like circumstances.