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activity additional agree agreement allowed amount applied basis capital claimed Commissioner considered contract contributions corporation cost Court December decision deduction deficiency determined distribution effect entered entitled evidence expenses facts Federal fees filed follows further gain granted gross held holding Income Tax Income Tax Regs individual interest Internal Revenue Internal Revenue Code inventory investment Investors involved issue Judge liability license limited loss meaning method motion notice operations opinion paid parties partnership payments percent period petition petitioner petitioner's position present prior profit purchase pursuant reason received record references reflect regulations respect respondent respondent's result Rule sell share sold structure substantial supra Tax Court tax return taxable taxpayer term territorial tion trade transactions transfer trust United
Page 444 - The most stringent protection of free speech would not protect a man in falsely shouting fire in a theatre and causing a panic.
Page 917 - ... that a trade secret or other confidential research, development, or commercial information not be disclosed or be disclosed only in a designated way; (8) that the parties simultaneously file specified documents or information enclosed in sealed envelopes to be opened as directed by the court.
Page 926 - The proceedings of the Tax Court and its divisions shall be conducted in accordance with such rules of practice and procedure (other than rules of evidence) as the Tax Court may prescribe and in accordance with the rules of evidence applicable in trials without a jury in the United States District Court of the District of Columbia.
Page 540 - Where before the expiration of the time prescribed in section 275 for the assessment of the tax, both the Commissioner and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.
Page 1132 - In lieu of any order or in addition thereto, the court shall require the party failing to act or the attorney advising him or both to pay the reasonable expenses, including attorney's fees, caused by the failure, unless the court finds that the failure was substantially justified or that other circumstances make an award of expenses unjust.
Page 533 - No suit or proceeding shall be maintained in any court for the recovery of any internal revenue tax alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected without authority, or of any sum alleged to have been excessive or in any manner wrongfully collected...
Page 612 - Issued, and if substantially all such stock (other than nonvoting preferred stock, the owners of which are not entitled or permitted to participate, directly or indirectly in the profits of the association, upon dissolution or otherwise, beyond the fixed dividends) is owned by producers who market their products or purchase the'ir supplies and equipment through the association...
Page 370 - All agreements for pecuniary considerations to control the business operations of the government, or the regular administration of justice, or the appointments to public offices, or the ordinary course of legislation, are void as against public policy, without reference to the question whether improper means are contemplated or used in their execution. The law looks to the general tendency of such agreements, and it closes the door to temptation by refusing them recognition in any of the courts of...