Reports of the Tax Court of the United States, Volume 63U.S. Government Printing Office, 1975 |
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Common terms and phrases
accounts receivable addition affirmed agreement Agway amendment amount applicable assets bad debt basis beneficiary benefit Branjon carryback certiorari claimed COMMISSIONER OF INTERNAL Computax contract corporation decedent decedent's decision deduction Derby disallowed employees entitled estate tax excise tax expenses Federal income tax fifth amendment filed follows Freeport gift tax gross income held Hendry hereinafter income interest Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service issue January lease Lee County liability liquidation loans loss merger notice of deficiency Old Eastern operating opinion ordinary income paid parties partnership payment Pelco percent petition petitioner petitioner's prior Pritchett Pritchett-Longenecker property purchase purposes pursuant qualify real estate received records rental reported reserve residence respect Respondent determined RESPONDENT Docket respondent's Rule shareholders shares sold stipulated subsection supra TASCO Tax Court taxable taxpayer transaction transfer trust Vinemore wagers
Popular passages
Page 160 - capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include 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 262 - ... (a) General rule. If contributions are paid by an employer to or under a stock bonus, pension, profit-sharing, or annuity plan, or If compensation is paid or accrued on account of any employee under a plan deferring the receipt of such compensation, such contributions or compensation shall not be deductible under section 162 (relating to trade or business expenses) or section 212 (relating to expenses for the production of Income) but If they satisfy the conditions of either of such sections...
Page 89 - Trade or business expenses — (a) In general. There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including — (1) A reasonable allowance for salaries or other compensation for personal services actually rendered...
Page 482 - 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 to sell and both having reasonable knowledge of relevant facts.
Page 303 - The remedial character of sanctions imposing additions to a tax has been made clear by this Court in passing upon similar legislation. They are provided primarily as a safeguard for the protection of the revenue and to reimburse the Government for the heavy expense, of investigation and the loss res.ulting from the taxpayer's fraud.
Page 343 - ... the realization by the corporation manufacturing, constructing, producing or purchasing the property of a substantial part of the taxable income to be derived from such property, and (B) the realization by such shareholders of gain attributable to such property.
Page 421 - See section 179 and § 1.179-1 for a further description of the term "reasonable allowance." (b) Useful life. For the purpose of section 167 the estimated useful life of an asset is not necessarily the useful life inherent in the asset but is the period over which the asset may reasonably be expected to be useful to the taxpayer in his trade or business or in the production of his income.
Page 400 - ... to have the character which it would have had in the hands of the decedent if the decedent had lived and received such amount.
Page 30 - Carryovers in certain corporate acquisitions — (a) General rule. In the case of the acquisition of assets of a corporation by another corporation — (1) In a distribution to such other corporation to which section 332 (relating to liquidations of subsidiaries) applies, except in a case in which the basis of the assets distributed is determined under section...
Page 505 - In the case of an individual, there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year — (1) For the production or collection of income; (2) For the management, conservation, or maintenance of property held for the production of income; or (3) In connection with the determination, collection, or refund of any tax.