Reports of the United States Tax Court, Volume 65The Court, 1975 |
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2d Cir 5th Cir affd agreement allowed amended amount applied assets basis beneficiaries carryback cash claim computed Congress corporation CR trusts Crow-Burlingame death decedent decedent's December 31 depreciation distribution Easy Rider election entitled escrow estate tax evidence expenses fact Federal income tax filed gift tax gross income held hereinafter Hotel Florence included Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service investment credit issue lease liability liquidation loan loss marital deduction Nor-West notice of deficiency operating opinion ordinary income ownership paid parties partnership payments percent petition petitioner petitioner's postmark prior purchase purposes pursuant received regulations Rept respect Respondent determined RESPONDENT Docket respondent's rule section 38 property shareholders shares spouse statute statutory subsidiary supra Tax Court tax return taxable income taxpayer trade or business transaction transfer trust instrument United usufruct
Popular passages
Page 259 - The following acts, or any of them, are crimes coming within the jurisdiction of the Tribunal for which there shall be individual responsibility : (a) Crimes against peace : namely, planning, preparation, initiation, or waging of a war of aggression, or a war in violation of international treaties, agreements or assurances, or participation in a common plan or conspiracy for the accomplishment of any of the foregoing ; (6) War Crimes : namely, violations of the laws or customs of war.
Page 191 - ... an amount equal to the value of any interest in property which passes or has passed from the decedent to his surviving spouse, but only to the extent that such interest is included in determining the value of the gross estate.
Page 4 - Business' is a very comprehensive term and embraces everything about which a person can be employed. Black's Law Diet., 158, citing People v. Commissioners of Taxes, 23 NY 242, 244, 'that which occupies the time, attention and labor of men for the purpose of a livelihood or profit.
Page 134 - Future interests" is a legal term, and includes reversions, remainders, and other interests or estates, whether vested or contingent, and whether or not supported by a particular interest or estate, which are limited to commence in use, possession or enjoyment at some future date or time.
Page 247 - ... (A) if an interest in such property passes or has passed (for less than an adequate and full consideration in money or money's worth) from the decedent to any person other than such surviving spouse...
Page 485 - That the value of foreign coin as expressed in the money of account of the United States shall be that of the pure metal of such coin of standard value ; and the values of the standard coins in circulation of the various nations of the world shall be estimated annually by the Director of the Mint, and be proclaimed on the first day of January by the Secretary of the Treasury.
Page 700 - 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...
Page 715 - No Act of Congress shall be construed to invalidate, impair. or supersede any law enacted by any State for the purpose of regulating the business of insurance...
Page 208 - partnership" includes a syndicate group, pool, joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title, a trust or estate or a corporation; and the term "partner" includes a member in such a syndicate, group, pool, joint venture, or organization.
Page 304 - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death(1) The possession or enjoyment of, or the right to the income from, the property, or (2) 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.