Reports of the Tax Court of the United States, Volume 5U.S. Government Printing Office, 1946 Final issue of each volume includes table of cases reported in the volume. |
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Common terms and phrases
agreed amount assets Awrey basis beneficiaries Boltz calendar capital stock cash certificate certiorari claim COMMISSIONER OF INTERNAL common stock computing contends contract corporation cost Court death decedent decedent's December 31 deduction deficiency determined disallowed distribution dividends Docket earnings and profits excess profits tax exchange executors expenses filed FINDINGS OF FACT follows fund gift tax gross estate gross income held Helvering husband included income tax income tax return interest Internal Revenue Code issue January Koppy lease liability liquidation Ludington McAllister operation opinion paid par value parties partners payable payment Pepsi-Cola percent period peti petitioner petitioner's preferred stock prior profits net income purchase question received respect respondent respondent's Revenue Act salary section 112 shares statute stipulated stockholders supra tax purposes tax return taxable taxpayer thereof tion tioner transaction transfer treasury stock trust instrument wife William W
Popular passages
Page 651 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...
Page 702 - ... the acquisition by one corporation in exchange solely for all or a part of its voting stock of at least 80 per centum of the voting stock and at least 80 per centum of the total number of shares of all other classes of stock of another corporation...
Page 741 - ... 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 469 - 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 Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses...
Page 702 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 405 - 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 741 - ... 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 82 - All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, * * « ***** "(2) Non-trade or non-business expenses. In the case of an individual, all the ordinary and necessary expenses paid or incurred during the taxable year for the production or collection of income, or for the management, conservation, or maintenance of property held for the production of income.
Page 311 - ... 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 325 - 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...