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Accordingly acquired actual Advice allowed amended amount annuity apply assets basis capital charitable computed considered contract contribution controlled corporation cost Court deduction deemed defined depreciation described determined DISC distribution dividend effect election employee example exchange exempt expenses facts Federal income filed foreign funds gain gift gross income held holds imposed income tax individual interest Internal Revenue Internal Revenue Code investment issue limited loan loss meaning ment method operating organization paid paragraph payment percent performed period person placed portion prior provides purchase pursuant qualified reason received regulations relating requested reserve respect result Revenue Code rules separate share shareholders subparagraph taxable taxpayer term tion trade transaction transfer treated trust United utility vides
Page 95 - ... 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...
Page 264 - ... Generally the relationship of employer and employee exists when the person for whom services are performed has the right to control and direct the individual who performs the services, not only as to the result to be accomplished by the work but also as to the details and means by which that result is accomplished. That is, an employee is subject to the will and control of the employer not only as to what shall be done but how it shall be done.
Page 228 - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 73 - Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate ; 3.
Page 72 - For the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including amounts paid for accident or health insurance) , or (B) For transportation primarily for and essential to medical care referred to in subparagraph (A).
Page 183 - States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses, and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income.
Page 79 - 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 79 - For purposes of this subtitle, the term "dividend" means any distribution of property made by a corporation to its shareholders — (1) Out of its earnings and profits accumulated after February 28, 1913, or (2) Out of its earnings and profits of the taxable year (computed as of the close of the taxable year without diminution by reason of any distributions made during the taxable year) , without regard to the amount of the earnings and profits at the time ihe distribution was made.
Page 33 - For purposes of this section, the term "charitable contribution" means a contribution or gift to or for the use of — (1) A State, a Territory, a possession of the United States, or any political subdivision of any of the foregoing, or the United States or the District of Columbia, but only if the contribution or gift is made for exclusively public purposes.