Reports of the Tax Court of the United States, Volume 14U.S. Government Printing Office, 1950 |
Other editions - View all
Common terms and phrases
acquired adjustment agreement amount assets average base period bank basis beneficiary bonds cash cent certificates certiorari claimed COMMISSIONER OF INTERNAL common stock community property computing contends contract corporation cost Court death decedent decedent's December 28 December 31 deductions deficiency depreciation determined disallowed distribution dividends Docket earnings entitled estate tax excess profits tax expenses Fageol filed FINDINGS OF FACT fiscal follows Funk gift tax gross estate gross income Hall-Scott held Helen Saunders Helvering included income tax income tax returns indebtedness interest Internal Revenue Code issue January ment mortgage operation paid partners partnership patents payable payment pension period net income peti petitioner petitioner's policies prior proceeding purchase purpose received renegotiation respect respondent respondent's salary section 107 section 722 shares stipulated stockholders supra taxable taxpayer thereof tion tioner transfer trust trust instrument United wife York
Popular passages
Page 498 - ... gains, profits, and income derived from salaries, wages, or compensation for personal service of whatever kind and in whatever form paid...
Page 297 - 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 6 - 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 729 - The net income shall be computed upon the basis of the taxpayer's annual accounting period (fiscal year or calendar year, as the case may be) 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 172 - All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually rendered...
Page 119 - ... the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Page 577 - 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 329 - ... 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, or where the decedent relinquished any such power in contemplation of his death.
Page 605 - Secretary or his delegate not to be discriminatory in favor of employees who are officers, shareholders, persons whose principal duties consist in supervising the work of other employees, or highly compensated employees...
Page 297 - 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...