Reports of the Tax Court of the United States, Volume 16U.S. Government Printing Office, 1951 |
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Common terms and phrases
accrual acquired adjustment agreement amount annuity average base period bank basis beneficiary capital assets capital gain cash cent claimed COMMISSIONER OF INTERNAL computed contract corporation cost coupons Court death decedent decedent's December 29 December 31 deduction deficiency determined disallowed distribution dividends Docket entitled estate tax excess profits credit excess profits tax exchange executors expenses February 28 filed FINDINGS OF FACT follows gross income held hereinafter included income tax income tax return interest Internal Revenue Code inventory investment involved issue January June 30 lease loss ment operation ordinary income paid parties partners partnership payment period net income peti petitioner petitioner's preferred stock premiums prior purchase receipts received refund renegotiation respect respondent respondent's sale to customers sales companies section 722 shares sold Southern and Atlantic stipulated stockholders supra taxable year ended taxpayer thereof tion tioner transaction transfer trust Western Union wife York York Mutual
Popular passages
Page 594 - ... 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 406 - gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service ... of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income...
Page 292 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other 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, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Page 345 - General rule. — (1) Decree of divorce or separate maintenance. — If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance...
Page 368 - Amounts distributed in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock, and amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the stock.
Page 826 - In the hands of the transferor corporation, and the principal purpose for which such acquisition was made is evasion or avoidance of Federal Income tax by securing the benefit of a deduction, credit, or other allowance...
Page 191 - To the extent of the amount receivable by all other beneficiaries as Insurance under policies...
Page 26 - taxable year" means the calendar year, or the fiscal year ending during such calendar year, upon the basis of which the net income is computed under section 212 or 232. The term "fiscal year" means an accounting period of twelve months ending on the last day of any month other than December. The term "taxable year...
Page 514 - ... under which he has retained 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— (1) the possession or enjoyment of, or the right to the income from, the property...
Page 340 - The Government may look at actualities and upon determination that the form employed for doing business or carrying out the challenged tax event is unreal or a sham may sustain or disregard the effect of the fiction as best serves the purposes of the tax statute.