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able acquired adjusted affiliated alien allowed amended amount application assets basis bonds calendar claim Code Commissioner compensation completed computed considered consolidated contract convention corporation cost December 31 deduction derived determined distribution dividends earnings effect election enterprise example excess profits exchange exempt expenses extent filed foreign Form gain gross income imposed included income tax individual interest Internal Revenue Internal Revenue Code inventory issued January laws less liability limitations liquidation March means ment method months net income nonresident obligations operating loss organization paid paragraph payment percent period person poration portion preceding prior profits provisions purchase reason received regulations relating resident respect section 112 section 23 securities share sources subcontract surtax taxable years beginning taxpayer term thereof tion trade treated trust United Kingdom
Page 535 - ... (B) from a foreign corporation unless less than 50 per centum of the gross income of such foreign corporation for the three-year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was derived from sources within the United States as determined under the provisions of this section...
Page 309 - An obligation of the United States or any of its possessions, or of a State or Territory, or any political subdivision thereof, or of the District of Columbia, issued on or after March 1, 1941, on a discount basis and payable without interest at a fixed maturity date not exceeding one year from the date of issue. §1.1221-1 Meaning of terms. (a) The term "capital assets" includes all classes of property not specifically excluded by section 1221.
Page 271 - ... visual acuity is greater than 20/200 but is accompanied by a limitation in the fields of vision such that the widest diameter of the visual field subtends an angle no greater than 20 degrees.
Page 334 - ... (2) In the payment of any contributions, a fractional part of a cent shall be disregarded unless it amounts to one-half cent or more, in which case it shall be increased to 1 cent.
Page 422 - DEFINITION OF PARTIAL LIQUIDATION. — As used in this section the term "amounts distributed in partial liquidation" means a distribution by a corporation in complete cancellation or redemption of a part of its stock, or one of a series of distributions in complete cancellation or redemption of all or a portion of its stock.
Page 221 - When, through some change in business conditions, the usefulness in the business of some or all of the capital assets is suddenly terminated, so that the taxpayer discontinues the business or discards such assets permanently from use in such business, he may claim as a loss for the year in which he takes such action the difference between the basis (adjusted as provided in section 113 (b) and article 113 (a) (14)-1, 113(b)-l', and 113(b)-2) and the salvage value of the property.
Page 372 - Indies, and which satisfies the following conditions: (1) If 95 percent or more of the gross income of such domestic corporation for the 3-year period immediately preceding the close of the taxable year (or for such part of such period during which the corporation was in existence) was derived from sources...
Page 174 - So also if the corporation receives its own stocks as consideration upon the sale of property by it, or in satisfaction of indebtedness to it, the gain or loss resulting is to be computed in the same manner as though the payment had been made in any other property. Any gain derived from such transactions is subject to tax, and any loss sustained is allowable as a deduction where permitted by the provisions of the Internal Revenue Code.
Page 262 - ... if all provisions of the plan which are necessary to satisfy such requirements are in effect by the end of such period and have been made effective for all purposes with respect to the whole of such period.