Reports of the Tax Court of the United States, Volume 39U.S. Government Printing Office, 1963 |
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Common terms and phrases
acquired agreed agreement amount apply assets August 31 bank basis capital gain cash certiorari claimed Clyborne coal Company contends contract contractor corporation cost Court decedent decedent's December 31 deduction deficiency director of internal distribution district director dividends Docket East Islip employee estate tax excess exemption expenses facts fair market value Federal income tax fees filed follows funds gift tax gross income held hereinafter included income tax return installment interest Internal Revenue Code issue Jarboe joint venture lease liability liquidation loans loss marital deduction ment mortgages operating ordinary income paid Paragon parties partnership payments percent peti petitioner petitioner's Pinal County prior profits purchase purposes pursuant Ralston Purina Company received Reffett respect Respondent determined respondent's royalty September 30 shares sold spouse stipulated stockholders supra taxable income taxpayer tion tioner tract transaction transfer trust United
Popular passages
Page 666 - ... Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not...
Page 50 - ... 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, then the gain, if any, to the recipient shall be recognized, but in an amount not in excess of the sum of such money and the fair market value of such other property.
Page 49 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 394 - reorganization' means (A) a statutory merger or consolidation, or (B) the acquisition by one corporation in exchange solely for all or a part of its voting stock: of at least 80 per centum of the voting stock and at least 80 per centum of the total number of shares of all other classes of stock of another corporation...
Page 368 - For purposes of the tax imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate the exemption and deductions provided for in this part.
Page 432 - CONVERSIONS. (a) GENERAL RULE. — If, during the taxable year, the recognized gains on sales or exchanges of property used in the trade or business, plus the recognized gains from the compulsory or involuntary conversion (as a result of destruction in whole or in part, theft or seizure, or an exercise of the power of requisition or condemnation or the threat or imminence thereof...
Page 447 - paid or accrued" or "paid or Incurred", dependent upon the method of accounting upon the basis of which the net income Is computed, unless in order to clearly reflect the Income the deductions or credits should be taken as of a different period. • * * Sec. 48. Definitions. When used in this chapter — (c) "paid or Incurred," "paid or accrued." The terms "paid or Incurred
Page 248 - ... the principal purpose for which such acquisition was made is evasion or avoidance of Federal income tax by securing the benefit of a deduction, credit, or other allowance which such person or corporation would not otherwise enjoy, then the Secretary may disallow such deduction, credit, or other allowance.
Page 121 - 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 or a corporation: and the term "partner" Includes a member in such a syndicate, group, pool, joint venture, or organization.
Page 464 - To the extent of the amount receivable by the executor as insurance under policies taken out by the decedent upon his own life; and to the extent of the excess over $40,000 of the amount receivable by all other beneficiaries as insurance under policies taken out by the decedent upon his own life.