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acquired additional affiliated agreed agreement allowed amount applied assets assignment authorized basis Board capital stock cash Central City claim Commissioner common computed consolidated contends contract corporation cost court death decedent December decision deduction deficiency determined directors distribution dividend earnings effect entered evidence exchange executed Executors expenses facts filed FINDINGS follows fund gain gross held hold included income tax interest INTERNAL investment issue January John June land liability liquidation loss Lumber March National Bank notes officers operating opinion organized paid parties payment percent period petitioner petitioner's policies preferred prior proceeding profits purchase question received reported representing reserve respect respondent Revenue Act rule securities separate shares sold statute stipulated stockholders taxable thereof tion transaction transfer trust United wife York
Page 580 - If an exchange would be within the provisions of subsections (b) (1), (2), (3), or (4) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 803 - 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 417 - ... of a kind tending to increase the value of the property assessed, and not including any amount paid out for new buildings, or for permanent improvements or betterments made to increase the value of any property.
Page 580 - ... has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be taxed as a gain from the exchange of property.
Page 636 - To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, 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...
Page 661 - For the purpose of this rule, a dealer in securities is a merchant of securities, whether an individual, partnership, or corporation, with an established place of business, regularly engaged in the purchase of securities and their resale to customers; that is, one who as a merchant buys securities and sells them to customers with a view to the gains and profits that may be derived therefrom.
Page 532 - ... shall be allocated between the properties (other than money) received, and for the purpose of the allocation there shall be assigned to such other property an amount equivalent to its fair market value at the date of the exchange.
Page 277 - 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 694 - If the property was acquired after December 31, 1920, by a transfer in trust (other than by a transfer in trust by a bequest or devise) the basis shall be the same as it would be in the hands of the grantor, increased in the amount of gain or decreased in the amount of loss recognized to the grantor upon such transfer under the law applicable to the year in which the transfer was made; (4) GIFT OR TRANSFER IN TRUST BEFORE JANUARY 1, 1921.
Page 17 - 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.