Reports of the Tax Court of the United States, Volume 46U.S. Government Printing Office, 1966 Final issue of each volume includes table of cases reported in the volume. |
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Common terms and phrases
acquired agreed agreement amount annuity apply assets basis capital gain cash certiorari charitable claimed Commissioner contract contribution corporation cost Court death decedent decedent's deduction distribution district director dividend earnings and profits employee entitled estate tax exempt expenses fair market value Federal income tax filed Frisco Railway gross estate gross income held income tax return indebtedness interest Internal Revenue Code Internal Revenue Service issue Jewelry June June 30 land lease liability license loan loss Lucile ment mortgage notice of deficiency October 30 operation opinion ordinary income paid parties partnership payable payments percent person peti petitioner petitioner's photoplays prior purchase purposes pursuant received residence respect Respondent determined RESPONDENT Docket respondent's Revolvex Rowatt sell shareholder shares sold statute Steinway & Sons stipulated stockholders supra taxable income taxpayer Thiokol tion tioner transaction transfer trust Turn-To
Popular passages
Page 417 - 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 46 - ... 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 333 - A transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders immediately before the transfer), or any combination thereof, is in control of the corporation to which the assets are transferred...
Page 341 - If an exchange would be within the provisions of subsection (b), (1), (2), (3), or (5) 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 333 - ... at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
Page 659 - In the case of a husband described in section 71, there shall be allowed as a deduction amounts includible under section 71 in the gross income of his wife, payment of which is made within the husband's taxable year. No deduction shall be allowed under the preceding sentence with respect to any payment if, by reason of section 71 (d) or 682, the amount thereof is not includible in the husband's gross income. (b) Cross reference. For definitions of "husband" and "wife", see section 7701 (a) (17).
Page 44 - Secretary, expended in the acquisition of other property similar or related in service or use to the property so converted. or in the acquisition of control of a corporation owning such other property or in the establishment of a replacement fund, no gain or loss shall be recognized.
Page 596 - 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 793 - Is dependent upon the performance of some act or the happening of a precedent event In order that It might become effective, no deduction is allowable unless the possibility that the charitable transfer will not become effective Is so remote as to be negligible.
Page 261 - ... shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.