Reports of the United States Tax Court, Volume 61U.S. Government Printing Office, 1973 |
Other editions - View all
Common terms and phrases
acquired affirming agreed agreement amount apply assets bank basis Bimini Run Canaveral Groves capital gain cash certiorari checks claimed common stock Company contract corporation Court decedent decedent's December December 31 decision deduction depreciation director distribution dividend embezzled employee exchange expenses fact fair market value Federal income tax filed gross income held Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue Kansas River lease liability loan ment notice of deficiency Old Nassau Oliver Oliver Corporation operating loss option ordinary income Otterville paid parties partnership patent payable payments percent period Perma-Line peti petitioner petitioner's prior Puerto Rico purchase purposes pursuant received redemption respect Respondent determined RESPONDENT Docket respondent's rule section 38 property shareholders shares statute stipulated supra taxable income taxpayer tion tioner trade or business transaction transfer trust United White Company White Motor
Popular passages
Page 364 - The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.
Page 22 - ... 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 756 - Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains...
Page 174 - In the case of a series of transactions, the date of the last such transaction) ; and (B) stock of the distributing corporation possessing 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 158 - If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance, the wife's gross income includes periodic payments (whether or not made at regular intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, in discharge of) a legal obligation which, because of the marital or family relationship, is imposed on or incurred by the husband under the decree or under a written instrument incident...
Page 759 - Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a): (1) CITIZENS AND DOMESTIC CORPORATIONS.— In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and (2) RESIDENT OF THE UNITED STATES OR PUERTO RICO.
Page 389 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind...
Page 34 - The amount of any money, or the fair market value of any property, received by a transferor partner in exchange for all or a part of his interest in the partnership attributable to...
Page 441 - ... loss year") shall be carried to the earliest of the taxable years to which (by reason of paragraph (1)) such loss may be carried. The portion of such loss which shall be carried to each of the other taxable years shall be the excess, if any, of the amount of such loss over the sum of the taxable income for each of the prior taxable years to which such loss may be carried.
Page 647 - ... gains, profits, and income derived from salaries, wages, or compensation for personal service ... of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived from any...