Reports of the Tax Court of the United States, Volume 48U.S. Government Printing Office, 1967 |
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Common terms and phrases
acquired adjusted agreed agreement amount application assets attorney Baker basis capital carryback certiorari charitable deduction claimed Commissioner companies computed contract corporation cost Court debt decedent decedent's December 31 decision depletion director of internal distribution district director dividends employees entitled expenses fair market value fees filed follows gift gross income held hereinafter Hickok belt husband included income tax return Internal Revenue Code Internal Revenue Service inventory involved issue January January 31 joint June lease liability loan marital deduction ment merger Muzak notice of deficiency operating loss opinion ordinary income paid parties partnership payment percent period peti petitioner petitioner's Portugalete premiums prior purchase purposes pursuant received remainderman reorganization respect Respondent determined RESPONDENT Docket respondent's shares statute stipulated stockholders supra taxable income taxpayer terminated tion tioner tract transaction transfer trust W. T. Grant Co WHRW wife
Popular passages
Page 390 - 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 263 - ... the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom ; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Page 283 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 887 - property used in the trade or business" means property used in the trade or business, of a character which is subject to the allowance for depreciation provided in section 167, held for more than 6 months, and real property used in the trade or business...
Page 160 - Secretary, expended in the acquisition of other property similar or related in service or use to the property so converted, or in the acquisition of control of a corporation owning such other property, or in the establishment of a replacement fund, no gain or loss shall be recognized. If any part of the money is not so expended...
Page 936 - No taxpayer shall be subjected to unnecessary examination or Investigations, and only one Inspection of a taxpayer's books of account shall be made for each taxable year unless the taxpayer requests otherwise or unless the Secretary or his delegate, after investigation, notifies the taxpayer In writIng that an additional Inspection Is necessary.
Page 772 - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 25 - States, any claim upon or against the Government of the United States, or any department or officer thereof, knowing such claim to be false, fictitious, or fraudulent; or whoever, for the purpose of obtaining or aiding to obtain the payment or approval of...
Page 419 - LOSSES. (a) General Rule. — There shall be allowed as a deduction any loss sustained during the taxable year and not compensated for by insurance or otherwise.
Page 80 - IB for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who are officers, shareholders, persona whose principal duties consist in supervising the work of other employees, or highly compensated employees...