Reports of the United States Tax Court, Volume 65United States Tax Court, 1975 |
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Common terms and phrases
2d Cir 5th Cir affd agreement allowed amended amount applicable assets basis beneficiaries carryback cash claim computed Congress corporation CR trusts Crow-Burlingame death decedent decedent's December 31 decision depreciation distribution Easy Rider election entitled escrow estate tax expenses facts Federal income tax filed gift tax gross income held hereinafter Hotel Florence included Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service investment credit issue lease liability liquidation loan loss marital deduction Nor-West notice of deficiency operating opinion ordinary income ownership paid parties partnership payments percent petition petitioner petitioner's postmark prior purchase purposes pursuant received regulations Rept respect Respondent determined RESPONDENT Docket respondent's rule section 38 property shareholders shares statute statutory subsidiary supra Tax Court tax return taxable income taxpayer trade or business transaction transfer trust instrument United usufruct
Popular passages
Page 1008 - To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or "(c) To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person, in connection with the purchase or sale of any security.
Page 769 - At any time during the last half of the taxable year more than 50 percent In value of Its outstanding stock Is owned, directly or Indirectly, by or for not more than 5 Individuals.
Page 970 - 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 245 - ... (A) if an interest in such property passes or has passed (for less than an adequate and full consideration in money or money's worth) from the decedent to any person other than such surviving spouse...
Page 257 - The following acts or any of them, are crimes coming within the jurisdiction of the Tribunal for which there shall be individual responsibility : "(a) Crimes Against Peace: namely, planning, preparation, initiation or waging of a war of aggression, or a war in violation of international treaties, agreements or assurances, or participation in a common plan or conspiracy for the accomplishment of any of the foregoing.
Page 491 - That the value of foreign coin as expressed in the money of account of the United States shall be that of the pure metal of such coin of standard value ; and the values of the standard coins in circulation of the various nations of the world shall be estimated annually by the Director of the Mint, and be proclaimed on the first day of January by the Secretary of the Treasury.
Page 257 - War crimes : namely, violations of the laws or customs of war. Such violations shall include, but not be limited to, murder, ill-treatment or deportation to slave labour or for any other purpose of civilian population of or in occupied territory, murder or illtreatment of prisoners of war or persons on the seas, killing of hostages, plunder of public or private property, wanton destruction of cities, towns or villages, or devastation not justified by military...
Page 1117 - unrelated business taxable Income" means the gross Income derived by any organization from any unrelated trade or business (as defined In section 513) regularly carried on by it, less the deductions allowed by this chapter which are directly connected with the carrying on of such trade or business, both computed with the exceptions, additions, and limitations provided In subsection (b) . In the case of an organization described In section 511 which is a foreign organization, the unrelated business...
Page 429 - 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 302 - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...