Reports of the Tax Court of the United States, Volume 5U.S. Government Printing Office, 1945 |
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Common terms and phrases
amount assets Awrey basis beneficiaries capital stock cash certiorari claim COMMISSIONER OF INTERNAL common stock computing contends contract corporation corpus Court death decedent decedent's December 31 deduction deficiency determined disallowed distribution dividends Docket earnings and profits equity invested capital excess profits tax exchange executed executors expenses filed FINDINGS OF FACT follows fund futures contracts gift tax gross estate gross income held Helvering husband included income tax income tax return interest Internal Revenue Code issue January lease liability liquidation loss Ludington operating opinion paid par value parties partners payment percent period peti petitioner petitioner's preferred stock prior profits net income purchase question received referred respondent respondent's Revenue Act salaries section 112 settlor shares statute stipulated stockholders supra tax purposes tax return taxable taxpayer thereof tion tioner transaction transfer treasury stock trust estate trust instrument wife wool
Popular passages
Page 635 - ... 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 506 - partnership" Includes a syndicate, group, pool, Joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title, a trust or estate...
Page 310 - 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 648 - Increased In the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year In which the transfer was made.
Page 666 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 707 - The net income of the estate or trust shall be computed in the same manner and on the same basis as in the case of an individual...
Page 358 - ... (b) Source of distributions. For the purposes of this Act every distribution is made out of earnings or profits to the extent thereof, and from the most recently accumulated earnings or profits. Any earnings or profits accumulated, or increase in value of property accrued, before March 1, 1913, may be distributed exempt from tax, after the earnings and profits accumulated after February 28, 1913, have been distributed, but any such tax-free distribution shall be applied against and reduce the...
Page 402 - 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 132 - ... in accordance with the method of accounting regularly employed in keeping the books of such taxpayer; but if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income...
Page 390 - 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...