Reports of the Tax Court of the United States, Volume 58U.S. Government Printing Office, 1972 |
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affd agree agreement alimony allocation American Jewish Committee amount annuity applicable assets attorney basis beneficiary Bermuda trusts capital gain cash Cedar Homes certiorari claims Commissioner contends contract corporation Court Curtiss-Wright death decedent decedent's December 31 decision deduction distribution dividend earnings and profits employee entitled estate tax exclusionary rule facts Federal income tax Fehrs filed follows funds Golconda gross estate gross income held included Income Tax Regs income tax return installment interest Internal Revenue Code Internal Revenue Service investment issue lease liquidation loan ment opinion option ordinary income paid parties partnership patents payable payments percent period peti petitioner petitioner's preferred stock prior purchase purposes pursuant received redemption rental respect Respondent determined RESPONDENT Docket respondent's royalties rule Schmeer section 482 settlor shareholders shares stipulated supra Tacoma Mall taxable income taxpayer TIAA tion tioner transaction transfer United wife
Popular passages
Page 17 - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 410 - The legal right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid them, by means which the law permits, cannot be doubted.
Page 126 - In the case of a plan which provides contributions or benefits for employees some or all of whom are employees within the meaning of...
Page 460 - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses...
Page 460 - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses. if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 491 - If a trust is created or property is transferred for both a charitable and a private purpose, deduction may be taken of the value of the charitable beneficial interest only insofar as that interest is presently ascertainable, and hence severable from the noncharitable interest.
Page 241 - The gross estate shall include the value of an annuity or other payment receivable by any beneficiary by reason of surviving the decedent under any form of contract or agreement entered into after March 3, 1931 (other than as insurance under policies on the life of the decedent) , if, under such contract or agreement, an annuity or other payment...
Page 129 - Any transfer of a material part of his property in the nature of a final disposition or distribution thereof, made by the decedent within two years prior to his death without such a consideration, shall, unless shown to the contrary, be deemed to have been made in contemplation of death...
Page 509 - ... (b) Sales of realty and casual sales of personalty. — In the case (1) of a casual sale or other casual disposition of personal property (other than 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), for a. price exceeding $1,000...
Page 616 - Is divorced or legally separated from her husband under a decree of divorce or of separate maintenance...