Reports of the Tax Court of the United States, Volume 17U.S. Government Printing Office, 1952 |
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Common terms and phrases
agreed agreement amount annuity assets bank base period basis beneficiary capital gain cash cent claimed COMMISSIONER OF INTERNAL common stock Company computed contract cost Court death decedent decedent's December 31 deduction deficiency determined directors disallowed distribution dividends Docket Dubuque Packing Company earnings employee entitled excess profits tax expenses filed FINDINGS OF FACT follows funds gift gift tax gross estate gross income held hereinafter Hosiery included income tax income tax return interest Internal Revenue Code issue January L. L. Goodman lease liability Limbeck Llenroc loss ment net income operation option paid parties partnership payable payment peti petitioner petitioner's preferred stock premium prior production purchase pursuant received renegotiation respect respondent respondent's Roseland Sacramento Corporation salary section 23 securities settlor shares sold stipulated stockholders supra taxable taxpayer termination tion tioner trade or business transaction transfer trust wife
Popular passages
Page 738 - 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 822 - If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend...
Page 419 - ... 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 822 - 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 5 - 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 555 - ... any profit realized by him from any purchase and sale, or any sale and purchase, of any equity security of such issuer (other than an exempted security) within any period of less than six months, unless such security was acquired in good faith in connection with a debt previously contracted...
Page 18 - In the case of an individual, losses sustained during the taxable year and not compensated for by insurance or otherwise — (1) if incurred in trade or business; or (2) if incurred in any transaction entered into for profit, though not connected with the trade or business...
Page 317 - ... rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity...
Page 425 - ... 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) of property used in the trade or business...
Page 268 - 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...