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acquired agreed agreement alleged allowed amount appeal assets authorized Bank basis beneficiaries Board bonds carried cash claimed Coal Commissioner common Company computing consideration consolidated contends contract corporation cost Court death decedent December decision deduction deficiency determined distribution dividends Docket effect entered evidence exchange executors expenses facts fair market value filed FINDINGS follows funds gain gift gross held hold included income tax interest invested issue January land lease liability loss March Michigan notes operations opinion organized paid parties payment period petitioner petitioner's prior proceeding production profit purchase question realized reason received record referred reported representing respect respondent result Revenue Act Rule securities sell shares sold statute stipulation stockholders supra sustained taxable taxpayer thereof tion transaction transfer trust United wife
Page 7 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities In such corporation, and immediately after the exchange such person or persons are in control of the corporation...
Page 9 - Mother corporation) or (B) a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor, or its stockholders, or both, are in control of the corporation to which the assets are transferred ; or (C) a recapitalization or (D) a mere change in identity, form or place of organization however effected. (2) The term "a party to a reorganization...
Page 198 - A charity, in the legal sense, may be more fully defined as a gift, to be applied, consistently with existing laws, for the benefit of an indefinite number of persons, either by bringing their minds or hearts under the influence of education or religion, by relieving their bodies from disease, suffering or constraint, by assisting them to establish themselves in life, or by erecting or maintaining public buildings or works or otherwise lessening the burdens of government.
Page 592 - reorganization" means (A) a merger or consolidation (Including the acquisition by one corporation of at least a majority of the voting stock and at least a majority of the total number of shares of all other classes of stock of another corporation, or substantially all the properties of another corporation...
Page 692 - Any earnings or profits accumulated, or increase in value of property accrued, before March 1, 1913, may be distributed exempt from tax, after the earnings and profits accumulated after February 28, 1913, have been distributed...
Page 109 - That the value of the gross estate of the decedent shall be determined by including the value at the time of his death...
Page 719 - ... there shall be allowed as an additional deduction in computing the net income of the estate or trust the amount of the income of the estate or trust for its taxable year, which is properly paid or credited during such year to any legatee, heir, or beneficiary...
Page 300 - ... may be, applied to the payment of premiums upon policies of insurance on the life of the grantor (except policies of insurance irrevocably payable for the purposes and in the manner specified in section 23 (o), relating to the so-called "charitable contribution" deduction); then such part of the income of the trust shall be included in computing the net income of the grantor.
Page 211 - 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.