Reports of the Tax Court of the United States, Volume 19U.S. Government Printing Office, 1954 |
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Common terms and phrases
adjustment agreed agreement amount assets average base period basis beneficiary capital Carleton Macy cash cent claims collector of internal COMMISSIONER OF INTERNAL common stock computed constructive average base contract corporation cost Court death decedent decedent's December 31 deduction deficiency distributed dividends Docket employees entitled excess profits credit excess profits tax executors expenses filed FINDINGS OF FACT fiscal year ended follows gift tax gross income held Hens & Kelly included income tax income tax return interest Internal Revenue Code issue January July 31 June 30 Kelly Company lease Lessee lessor liability loan loss manufacture Maywood Park ment mining normal earnings operations paid Paine Webber parties partners partnership payments period net income peti petitioner petitioner's prior production purchase Ray Jackson received rental respect section 722 shares sold stipulated stockholders supra taxable taxpayer tion tioner transfer trust trust instruments wife
Popular passages
Page 107 - 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; traveling expenses (including the entire amount expended for meals and lodging) while away from home in the pursuit of a trade or business...
Page 837 - 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 or profits and income derived...
Page 238 - In the case of property held in trust, the allowable deduction shall be apportioned between the income beneficiaries and the trustee in accordance with the pertinent provisions of the instrument creating the trust, or, in the absence of such provisions, on the basis of the trust income allocable to each.
Page 368 - All interest paid or accrued within the taxable year on indebtedness, except on indebtedness incurred or continued to purchase or carry obligations or securities (other than obligations of the United States issued after September 24, 1917, and originally subscribed for by the taxpayer) the interest upon which is wholly exempt from taxation under this title...
Page 93 - Income which is to be distributed currently by the fiduciary to the beneficiaries, and income collected by a guardian of an infant which is to be held or distributed as the court may direct...
Page 381 - ... (b) Finality of agreements. — If such agreement Is approved by the Secretary, or the Undersecretary, within such time as may be stated in such agreement, or later agreed to, such agreement shall be final and conclusive, and, except upon a showing of fraud or malfeasance, or misrepresentation of a material fact — "(1) The case shall not be reopened as to the matters agreed upon or the agreement modified, by any officer, employee, or agent of the United States...
Page 368 - 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 92 - INCOME. The net income of the estate or trust shall be computed in the same manner and on the same basis as in the case of an individual...
Page 567 - ... 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, shall inure to and be recoverable by the issuer, irrespective of any intention on the part of such beneficial owner, director, or officer in entering into such transaction of holding the security purchased or of not repurchasing the security sold for a period exceeding six months.
Page 837 - 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.