What people are saying - Write a review
We haven't found any reviews in the usual places.
Other editions - View all
accounting acquired activity additional agree agreement allowed amount apply argues assets basis benefit capital cash claimed Coal Commissioner contract corporation cost Court December deductions deficiency determined distribution economic effect entered evidence executed expenses fact Federal fees filed follows Form franchise gross held holding income tax individual interest Internal Revenue Internal Revenue Code investment issue lease liability limited loss meaning method mineral mining nonrecourse notice obligation operating opinion organization paid parties partnership payment percent period petitioner petitioner's position principal prior production profit promissory note purchase reasonable received record references regulations reserves respect respondent respondent's result royalty Rule Service share straddle substantial supra Tax Regs tax return taxable taxpayer term terminals tion trade transaction transfer trust United
Page 121 - Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a): (1) CITIZENS AND DOMESTIC CORPORATIONS.— In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and (2) RESIDENT OF THE UNITED STATES OR PUERTO RICO.
Page 337 - An economic interest is possessed in every case in which the taxpayer has acquired by investment any interest in mineral in place or standing timber and secures, by any form of legal relationship, income derived from the extraction of the mineral or severance of the timber, to which he must look for a return of his capital.
Page 934 - ... in the year in which the taxes of the foreign country or the possession of the United States accrued, subject, however, to the conditions prescribed in subsection (c) of this section.
Page 568 - Except as provided in subsection (b), there shall be allowed as a deduction in computing taxable income all expenditures paid or incurred during the taxable year for the development of a mine or other natural deposit (other than an oil or gas well) if paid or incurred after the existence of ores or minerals in commercially marketable quantities has been disclosed.
Page 134 - If It were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain, If any, to the recipient shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property.
Page 476 - The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same provisions and limitations...
Page xvii - The amount of the tax previously determined shall be the excess of — "(1) the sum of (A) the amount shown as the tax by the taxpayer upon his return (determined as provided in section 271 (b) (1) and (3) ), if a return was made by the taxpayer and an amount was shown as the tax by the taxpayer thereon, plus...
Page 347 - ... the language of the statute is broad enough to provide, at least, for every case in which the taxpayer has acquired, by investment, any interest in the oil in place, and secures, by any form of legal relationship, income derived from the extraction of the oil, to which he must look for a return of his capital.