Reports of the Tax Court of the United States, Volume 5U.S. Government Printing Office, 1945 |
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Common terms and phrases
agreed amount assets August 31 Awrey basis beneficiaries capital stock cash certificate 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 excess profits tax exchange executed expenses filed FINDINGS OF FACT follows fund futures contracts gift 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 salary section 711 settlor shares statute stipulated stockholders supra tax purposes taxable taxpayer thereof tion tioner transaction transfer treasury stock trust estate trust instrument wife wool tops
Popular passages
Page 757 - 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 112 - ... 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 550 - Includes gains, profits, and income derived from salaries, wages, or compensation for personal service of whatever kind and In whatever form paid...
Page 267 - 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 662 - 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 631 - ... 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 878 - 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 sell and both having reasonable knowledge of relevant facts.
Page 769 - Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate; (3) Any amount expended in restoring property or in making good the exhaustion thereof for which an allowance is or has been made...
Page 533 - 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 466 - 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...