Reports of the Tax Court of the United States, Volume 44U.S. Government Printing Office, 1965 Final issue of each volume includes table of cases reported in the volume. |
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Common terms and phrases
agreed agreement allocation amount apply April 30 ASCAP assets bad debts bank basis capital gain cash claimed Commissioner computed contract corporation cost Court decedent decedent's December December 19 December 31 deduction director of internal distribution district director dividends employees evidence expenses fair market value Federal income tax filed Gibraltar gross income Gryzmish held included income tax return interest Internal Revenue Code issue January January 31 joint return Kuney Lamb County lease liability liquidation loan loss ment notes notice of deficiency operating opinion ordinary income paid parties partnership payment percent period Permian peti petitioner petitioner's prior purchase price purpose pursuant received rental respect Respondent determined respondent's Roy Stone securities shareholders shares sold SS Robin statute statutory stipulated stockholders Street corporation supra taxable income taxpayer tion tioner trade or business transaction transfer trust United wife
Popular passages
Page 60 - ... 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 172 - Basis. (a) Dealers in Personal Property. Under regulations prescribed by the Commissioner with the approval of the Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the gross profit realized or to be realized when payment is completed, bears to the total contract price.
Page 503 - A conveyance by a partner of his interest in the partnership does not of itself dissolve the partnership, nor, as against the other partners in the absence of agreement, entitle the assignee, during the continuance of the partnership, to interfere in the management or administration of the partnership business or affairs...
Page 46 - medical care" means amounts paid — (A) for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including...
Page 797 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.
Page 133 - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 172 - Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the total profit realized or to be realized when the payment is completed, bears to the total contract price.
Page 146 - ... prior to the satisfaction of all liabilities with respect to employees and their beneficiaries under tho trust, for any part of the corpus or income to be (within the taxable year or thereafter) used for, or diverted to, purposes other than for the exclusive benefit of his employees or their beneficiaries...
Page 90 - ... year) , without regard to the amount of the earnings and profits at the time the distribution was made.
Page 174 - The gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis provided in section 113 (b) for determining gain, and the loss shall be the excess of the adjusted basis provided in sucn section for determining loss over the amount realized. (b) AMOUNT REALIZED. — The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money)...