Reports of the Tax Court of the United States, Volume 44U.S. Government Printing Office, 1965 |
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Common terms and phrases
agreed agreement allocation amount apply April 30 ASCAP assets bad debts bank basis capital gain cash claimed Commissioner computed contract corporation cost Court decedent decedent's December 19 December 31 deduction director of internal distribution district director dividends employees entitled evidence expenses fair market value Federal income tax filed Gibraltar gross income Gryzmish held included income tax return interest Internal Revenue Code issue January Kuney Lamb County lease liability liquidation loan loss ment notes notice of deficiency operating opinion ordinary income paid parties partnership payment percent period Permian peti petitioner petitioner's prior purchase price purpose pursuant received record rental respect Respondent determined RESPONDENT Docket respondent's Roy Stone securities shareholders shares sold South Bend SS Robin statute statutory stipulated stockholders Street corporation supra taxable income taxpayer tion tioner trade or business transaction transfer United wife
Popular passages
Page 172 - ... (b) Sales of realty and casual sales of personalty. — In the case (1) of a casual sale or other casual disposition of personal property (other than property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year), for a. price exceeding $1,000...
Page 437 - Upon the adjudication of bankruptcy of any taxpayer in any bankruptcy proceeding or the appointment of a receiver for any taxpayer in any receivership proceeding before any court of the United States or of any State or Territory or of the District of Columbia, any deficiency (together with all interest, additional amounts, or additions to the tax provided for by law...
Page 133 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.
Page 46 - medical care" means amounts paid — (A) for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including...
Page 83 - If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 per centum of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 5 years after the return was filed.
Page 333 - Restrictions on examination of taxpayer. No taxpayer shall be subjected to unnecessary examination or investigations, and only one inspection of a taxpayer's books of account shall be made for each taxable year unless the taxpayer requests otherwise or unless the Secretary or his delegate, after investigation, notifies the taxpayer in writing that an additional inspection is necessary.
Page 354 - If contributions are paid by an employer to or under a stock bonus, pension, profit-sharing, or annuity plan, or If compensation is paid or accrued on account of any employee under a plan deferring the receipt of...
Page 172 - 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 133 - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 471 - The accumulated earnings tax Imposed by section 531 shall apply to every corporation (other than those described In subsection (b)) formed or availed of for the purpose of avoiding the Income tax with respect to Its shareholders or the shareholders of any other corporation, by permitting earnings and profits to accumulate Instead of being divided or distributed.