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activities additional agree agreement allowed amended amount apply assets basis benefit capital cash claimed Code Commissioner completion conclude considered constitute contends contract contributions corporation cost Court decision deduction deficiency determined distribution drilling effect employees entitled equipment evidence exempt expenses facts fair Federal filed funds further gain held hold income tax Income Tax Regs individual intended interest Internal Revenue Internal Revenue Code involved issue lease liability limited loan loss meaning notice obligation operators opinion organization paid parties partnership payment percent period petition petitioner petitioner's portion prior production purchase qualified reasonable received record reference regulations reserves respect respondent respondent's result rule Service shareholders shares supra tax return taxable taxpayer term trade transaction transfer treated trust United
Page 181 - Secretary or his delegate not to be discriminatory in favor of employees who are officers, shareholders, persons whose principal duties consist in supervising the work of other employees, or highly compensated employees; and (4) If the contributions or benefits provided under the plan do not discriminate in favor of employees who are officers, shareholders, persons whose principal duties consist in supervising the work of other employees, or highly compensated employees.
Page 372 - Upon the sale or exchange of property the entire amount of the gain or loss, determined under section 111, shall be recognized, except as hereinafter provided in this section.
Page 181 - (a) REQUIREMENTS FOR QUALIFICATION. — A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
Page 355 - Except as provided in this subsection, the term "section 38 property" means — (A) tangible personal property, or (B) other tangible property (not including a building and its structural components) but only if such property — (i) is used as an integral part of manufacturing, production, or extraction or of furnishing transportation, communications, electrical energy, gas, water, or sewage disposal services, or...
Page 686 - ... taxpayer is deceased, or is under a legal disability, or. in the case of a corporation, has terminated its existence.
Page 251 - ... the installment payments shall be treated as periodic payments for purposes of subsection (a), but (in the case of any one taxable year of the wife) only to the extent of 10 percent of the principal sum. For purposes of the preceding sentence, the part of any principal sum which is allocable to a period after the taxable year of the wife in which it is received shall be treated as an installment payment for the taxable year in which it is received.
Page 218 - Willfully makes and subscribes any return, statement, or other document, which contains or is verified by a written declaration that it is made under the penalties of perjury, and which he does not believe to be true and correct as to every material matter...
Page 235 - In any proceeding involving the issue whether the petitioner has been guilty of fraud with intent to evade tax, where no hearing has been held before the enactment of the Revenue Act of 1928, the burden of proof in respect of such issue shall be upon the Commissioner.