Reports of the Tax Court of the United States, Volume 46U.S. Government Printing Office, 1966 |
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Common terms and phrases
acquired agreed agreement amount annuity apply assets basis capital gain cash certiorari charitable claimed Commissioner contract contribution corporation cost Court death decedent decedent's deduction distribution district director dividend earnings and profits employee entitled estate tax exempt expenses fair market value farm Federal income tax filed Frisco Railway gross estate gross income held Hougen income tax returns indebtedness interest Internal Revenue Code Internal Revenue Service issue Jewelry June June 30 lease liability license loan loss Lucile ment notice of deficiency October 30 operation opinion option ordinary income paid parties partnership payable payments percent peti petitioner petitioner's Petitjean photoplays prior purchase purposes pursuant received residence respect Respondent determined RESPONDENT Docket respondent's Revolvex Rowatt sell shareholder shares sold Steinway Steinway & Sons stipulated stockholders supra taxable income taxpayer Thiokol tion tioner transaction transfer trust Turn-To
Popular passages
Page 269 - If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, penalty, additional amount, or addition to such tax, together with any costs that may accrue in addition thereto) shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.
Page 423 - To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend? or revoke...
Page 851 - partnership" includes a syndicate, group, pool, joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title, a trust or estate or a corporation; and the term "partner" includes a member in such a syndicate, group, pool, joint venture, or organization.
Page 40 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 44 - Secretary, expended in the acquisition of other property similar or related in service or use to the property so converted, or in the acquisition of control of a corporation owning such other property, or in the establishment of a replacement fund, no gain or loss shall be recognized. If any part of the money is not so expended...
Page 357 - One who comes to the United States for a definite purpose which in its nature may be promptly accomplished is a transient; but, if his purpose is of such a nature that an extended stay may be necessary for its accomplishment, and to that end the alien makes his home temporarily in the United States, he becomes a resident, though it may be his intention at all times to return to his domicile abroad when the purpose for which he came has been consummated or abandoned.
Page 407 - In their joint names and payable to either or the survivor, except such part thereof as may be shown to have originally belonged to such other person and never to have been received or acquired by the latter from the decedent for less than an adequate and full consideration in money or money's worth...
Page 339 - A transfer by a corporation of all or a part of its assets to another corporation If Immediately after the transfer the transferor, or one or more of Its shareholders (Including persons who were shareholders Immediately before the transfer) , or any combination thereof, Is in control of the corporation to which the assets are transferred...
Page 95 - March 1, 1913: but (2) for the purpose of the computation of earnings and profits of the corporation for any period beginning after February 28, 1913, shall be determined by using as the adjusted basis the adjusted basis (under the law applicable to the year in which the sale or other disposition was made) for determining gain.
Page 349 - Within the 12-month period beginning on the date of the adoption of such plan, all of the assets of the corporation are distributed in complete liquidation, less assets retained to meet claims, then no gain or loss shall be recognized to such corporation from the sale or exchange by It of property within such 12-month period.