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" Here we have the essential matter: not a gain accruing to capital, not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the capital however invested or employed,... "
Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ... - Page 67
1995
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Cases Decided in the United States Court of Claims ... with ..., Volume 123

United States. Court of Claims, Audrey Bernhardt - 1958 - 1044 pages
...court said, at page 207, with regard to the statutory language "gain derived from capital" : * * * Here we have the essential matter: not a gain accruing to capital, not a growth or increment of 509 Opinion of the Court value in the investment ; but a gain, a profit, something of exchangable value...
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The Federal Reporter, Volume 289

1923 - 1092 pages
...language of the Phellis Case) as "a gain derived from capital, not a gain accruing to capital, nor a growth or increment of value in the investment,...value, proceeding from the property, severed from capital, however invested, and coming in; that is, received or drawn by the claimant for his separate...
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Corporation Finance

Edward Sherwood Mead - 1920 - 504 pages
...misconceived. 'Derived — from — capital'; — 'the gain — derived — from — capital,' etc. Here we have the essential matter: not a gain accruing...or employed, and coming in, being 'derived,' that ia, received or drawn by the recipient (the taxpayer) for his separate use, benefit and disposal;—...
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Supreme Court Reporter, Volume 40

United States. Supreme Court - 1921 - 628 pages
...or misconceived. "Derived — from — capital"; "the gain — derived — from — capital," etc. Here we have the essential matter: not a gain accruing...exchangeable value, proceeding from the property, »evered from the capital, however Invested or employed, and coming in, being "derived" — that is,...
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Cases Argued and Decided in the Supreme Court of the United ..., Volumes 251-253

United States. Supreme Court - 1921 - 1362 pages
...misconceived, — "derived — from — capital,-" — "the gain — derived — from — capital" etc. Here we have the essential matter: not a gain accruing...a gain, a profit, something of exchangeable value p'oceeding from the property, severed from the capital, however invested or employed, and coming in,...
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United States Supreme Court Reports, Volume 64

United States. Supreme Court - 1921 - 1006 pages
...gain — derived — from — capital," etc. Here we have the essential matter: not a gain accruing 1o capital, not a growth or increment of value in the...a gain, a profit, something of exchangeable value p*oceeding from the property, severed from the capital, however invested or employed, and coming in,...
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Cumulative Bulletin ... Income Tax Rulings, Volume 2

United States. Bureau of Internal Revenue - 1921 - 778 pages
...of income states : Here we have the essential matter: Not a gain net-ruing to capital, not a ymtcth or increment of value in the investment, but a gain, a profit, something of exchangeable value prorreditifi from the property, xereretl from- the capital however invested or employed. * * *. Here...
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Cumulative Bulletin ... Income Tax Rulings, Issues 4-5

United States. Bureau of Internal Revenue - 1921 - 772 pages
...we have the essential matter: Not a gain net-ruing to capital, not a yrowth or increment of value iw the investment, but a gain, a profit, something of exchangeable value proceeding from the property, nerered from the capital however invested or employed. * * *. Here profit is made synonymous with income,...
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The Federal Income Tax

Thomas Sewall Adams - 1921 - 452 pages
...relying on the foregoing decisions when determining income tax liability. As quoted above, income is "not a growth or increment of value in the investment; but a gain . . . severed from . . . and coming in ... that is income derived from property . . . more important...
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United States Reports: ... and Rules Announced at ...

United States. Supreme Court - 1922 - 804 pages
...Eisner v. Macomber, 252 US 189, 207), a gain derived from capital, not a gain accruing to capital, nor a growth or increment of value in the investment,...property, severed from the capital however invested, and coming in, that is, received or drawn by the claimant for his separate use, benefit and disposal....
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