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additional adjustment agreed agreement allowed amended amount applicable assets base basis bonds capital cent charges claimed Commissioner compensation computed considered contends contract corporation cost Court death decedent decedent's December decision deduction deficiency Department determined distribution dividends earnings effect employees entered entitled estate tax excess profits executed executors expenses facts filed FINDINGS fiscal year ended follows gift gross held included income tax increase interest Internal Revenue Code involved issue January June liability limited liquidation loss ment officers operating opinion paid parties partnership payment period petitioner petitioner's policies present principal prior purchase question reason received record reported represented resident respect respondent result securities shares shows statute stipulated stockholders supra tax return taxable taxpayer term tion transfer trust United wife York
Page 832 - The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated, except real property situated outside of the United States
Page 588 - 22. GROSS INCOME. (a) GENERAL DEFINITION.—"Gross Income" Includes gains, profits, and Income derived from salaries, wages, or compensation for personal service • • • of whatever kind and In whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings In property, whether
Page 588 - 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
Page 98 - administration or settlement of the estate, and in the case of income which, in the discretion of the fiduciary, may be either distributed to the beneficiary or accumulated, there shall be allowed as an additional deduction In computing the net Income of the estate or trust the amount of the income of the estate or
Page 98 - SEC. 162. NET 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, except that— (b) There shall be allowed as an additional deduction in computing the net Income
Page 1001 - Section 41 of the Internal Revenue Code provides that net income shall be computed upon the basis of the taxpayer's annual accounting period 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
Page 98 - the estate or trust the amount of the Income of the estate or trust for its taxable year which Is to be distributed currently by the fiduciary to the beneficiaries, and the amount of the Income collected by a guardian of an Infant which Is to be held or distributed
Page 84 - if the losses of the taxable year from sales or exchanges of bonds, debentures, notes, or certificates, or other evidence of indebtedness issued by any corporation (including one issued by a government or political subdivision thereof) with interest coupons or In registered form, exceed
Page 386 - all of which said several classes of bonds and the interest thereon shall be exempt from the payment of all taxes or duties of the United States as well as from taxation in any form by or under state, municipal, or local authority.
Page 596 - PARTIAL LIQUIDATION.—As used in this section the term "amounts distributed In partial liquidation" means a distribution by a corporation in complete cancellation or redemption of a part of its stock, or one of a series of distributions in complete cancellation or redemption of all or a portion of Its stock.