Reports of the Tax Court of the United States, Volume 60U.S. Government Printing Office, 1973 |
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Common terms and phrases
acquired affd affirming agreement allocated allowed amended amount apply assets basis capital Carla Trading cash certiorari claimed collateral estoppel community property computed contends Coors Corp corporation cost Court debt decedent December 31 decision deduction depreciation disallowed district director dividends earnings election entitled estate tax facts fair market value Federal income tax filed gift gift tax gross income held Henry Schwartz included Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service inventory investment credit issue Joseph Coors July 31 liability loan loss ment notice of deficiency operation opinion ordinary income paid parties payments percent period peti petitioner petitioner's Philippine preferred stock prior profits purchase purposes pursuant received regulations respect Respondent determined RESPONDENT Docket respondent's Ross Glove Schatten-Cypress shareholders shares statute supra taxpayer tion tioner trade or business transaction transfer trust United
Popular passages
Page 355 - Options. If any person has an option to acquire stock, such stock shall be considered as owned by such person. For purposes of this paragraph, an option to acquire such an option, and each one of a series of such options, shall be considered as an option to acquire such stock.
Page 509 - Stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Page 302 - ... (1) Maintaining or improving skills required by the taxpayer in his employment or other trade or business, or (2) Meeting the express requirements of a taxpayer's employer, or the requirements of applicable law or regulations, imposed as a condition to the retention by the taxpayer of his salary, status or employment.
Page 134 - ... (4) amounts received as a pension, annuity, or similar allowance for personal injuries or sickness resulting from active service in the armed forces of any country...
Page 192 - ... (2) NON-TRADE OR NON-BUSINESS EXPENSES. — In the case of an individual, all the ordinary and necessary expenses paid or incurred during the taxable year for the production or collection of income, or for the management, conservation, or maintenance of property held for the production of income.
Page 269 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
Page 385 - It is a finality as to the claim or demand in controversy, concluding parties and those In privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand, but as to any other admissible matter which might have been offered for that purpose.
Page 479 - The accumulated earnings tax Imposed by section 531 shall apply to every corporation (other than those described In subsection (b) ) formed or availed of for the purpose of avoiding the Income tax with respect to Its shareholders or the shareholders of any other corporation, by permitting earnings and profits to accumulate Instead of being divided or distributed.
Page 73 - Such fair market value shall be the fair market value as of the first day of the taxable year in which such timber is cut, and shall thereafter be considered as the cost of such timber to the taxpayer for all purposes for which such cost is a necessary factor.
Page 385 - But where the second action between the same parties is upon a different claim or demand, the judgment in the prior action operates as an estoppel only as to those matters in issue or points controverted, upon the determination of which the finding or verdict was rendered.