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acquired addition allowed amended amount apply assets attributable authority basis beginning benefits bonds capital computing considered construction contained Contracting contributions corporation costs death December deduction defined described determined distribution dividends dollars effect election employee establishment example excess exchange exempt expenses facilities FACTS federal filed foreign France French fund gain gift gross income HOLDING imposed income tax individual interest Internal Revenue Internal Revenue Code investment issue January liability limitation loss meaning ment method obligations Office operation organization paid paragraph payment percent period person portion prior proceeds produced proposed provides purchase pursuant qualify reason received refunding regulations relating resident respect result Revenue Code rules taxable taxpayer term termination tion trade transfer Treasury treated trust United vides
Page 126 - Amounts distributed in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock, and amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the stock.
Page 206 - BASIS. (a) DEALERS IN PERSONAL PROPERTY. — Under regulations prescribed by the Commissioner with the approval of the Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the gross profit realized or to be realized when payment is completed, bears to the total contract price.
Page 109 - 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 168 - ... to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or to be of longcontinued and indefinite duration.
Page 303 - The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under the method of accounting used in computing taxable income, such amount is to be properly accounted for as of a different period.
Page 212 - Under an accrual method of accounting, an expense is deductible for the taxable year in which all the events have occurred which determine the fact of the liability and the amount thereof can be determined with reasonable accuracy.
Page 261 - ... if the method used does not clearly reflect income, the computation of taxable income shall be made under such method as, in the opinion of the Secretary or his delegate, does clearly reflect income.
Page 363 - An educational organization which normally maintains a regular faculty and curriculum and normally has a regularly enrolled body of pupils or students in attendance at the place where its educational activities are regularly carried on...
Page 439 - Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall...