Reports of the Tax Court of the United States, Volume 8U.S. Government Printing Office, 1947 |
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Common terms and phrases
Aero-Crafts agreed agreement Airco allowed amended amount annuity assets attorneys bad debt bank base period basis beneficiaries cash cent claimed COMMISSIONER OF INTERNAL community property computing contends contract corporation corpus cost Court death decedent decedent's December 31 deduction deficiency determined disallowed distribution dividends Docket employees entitled estate tax excess profits credit excess profits tax expenses filed FINDINGS OF FACT follows funds gift tax grantor gross estate gross income held Helvering included income tax income tax return interest Internal Revenue Code inventory invested issue January liquidation loss MacManus ment net income operation opinion paid parties partnership payable payment peti petitioner petitioner's preferred stock prior purchase question received respect respondent respondent's Revenue Act Rosboro salary Schuhmacher section 22 Settlor shares statute stockholders supra tax liability tax return taxable taxpayer thereof tion tioner transfer trust instrument wife
Popular passages
Page 342 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, 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...
Page 243 - 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 210 - No assessment of a deficiency in respect of the tax imposed by this chapter and no distraint or proceeding in court for its collection shall be made, begun, or prosecuted until such notice has been mailed to the taxpayer, nor until the expiration of such ninety-day period, nor, if a petition has been filed with the Board, until the decision of the Board has become final.
Page 440 - If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend...
Page 373 - 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 to be distributed currently...
Page 346 - ... in the case of income which, in the discretion of the fiduciary, may be either distributed to the beneficiary or accumulated, 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 209 - If in the case of any taxpayer, the Commissioner determines that there is a deficiency...
Page 540 - ... of the wife, owned by her before marriage, and that acquired afterwards by gift, bequest, devise, or descent, with the rents, Issues, and profits thereof, Is her separate property.
Page 397 - 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 274 - If the tax imposed by section 2101, or any estate, succession, legacy, or inheritance taxes, are, either by the terms of the will, by the law of the jurisdiction under which the estate is administered, or by the law of the jurisdiction imposing the particular tax, payable in whole or in part out of the bequests, legacies, or devises otherwise deductible under this paragraph, then the amount deductible under this paragraph shall be the amount of such bequests, legacies, or devises reduced by the amount...