Reports of the Tax Court of the United States, Volume 20U.S. Government Printing Office, 1954 |
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Common terms and phrases
adjustments agreement amended amount assets Ballet Ballet Theatre basis beneficiary Brazoria calendar capital gain capital stock cash cent claimed coal collector of internal COMMISSIONER OF INTERNAL computed contends contract corporation cost Court decedent decedent's December 31 decision deduction deficiency disallowed distribution dividend Docket earnings excess profits credit excess profits tax exchange expenses filed FINDINGS OF FACT fiscal year ended follows Grand Rapids gross income held included income tax income tax return interest Internal Revenue Code Isidor Straus issue July July 31 June June 30 Lake Eloise lease liability loss ment Mokan operating ordinary income paid Panhandle Eastern parties partnership payable payment period net income peti petitioner petitioner's preferred stock premiums prior purchase pursuant received refund renegotiation respondent's Rule 50 section 722 shares sold stipulated stockholders supra taxable taxpayer Texplant tion tioner transaction transfer trust instrument United wife
Popular passages
Page 461 - All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually rendered; traveling expenses (including the entire amount expended for meals and lodging) while away from home in the pursuit of a trade or business...
Page 271 - 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 61 - Deductions otherwise allowed by law not attributable to the operation of a trade or business regularly carried on by the taxpayer...
Page 111 - 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 703 - ... 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 593 - December 31, 1920, by a corporation — (A) by the Issuance of Its stock or securities In connection with a transaction described In section 112 (b) (5) (Including, also, cases where part of the consideration for the transfer of such property to the corporation was property or money, In addition to such stock or securities), or (B) as paid-in surplus or as a contribution to capital, then the basis shall be the same as It would be In the hands of the transferor...
Page 209 - ... property used in the trade or business and capital assets held for more than 6 months into other property or money, exceed the recognized losses from such sales, exchanges, and conversions, such gains and losses shall be considered as gains and losses from sales or exchanges of capital assets held for more than в months.
Page 258 - 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 110 - December 31, 1917, by a corporation in connection with a reorganization, and immediately after the transfer an interest or control in such property of 80 per centum or more remained in the same persons or any of them, then the basis shall be the same as it would be in the hands of the transferor increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such...
Page 222 - Income attributable to the recovery during the taxable year of a bad debt, prior tax, or delinquency amount, to the extent of the amount of the recovery exclusion with respect to such debt, tax, or amount. For the purposes of this paragraph: (A) Definition of Bad Debt. — The term "bad debt...