Reports of the Tax Court of the United States, Volume 9U.S. Government Printing Office, 1948 |
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Common terms and phrases
adjustment agreement amended amount assets August 31 basis beneficiary bonds cash cent claimed COMMISSIONER OF INTERNAL compensation computing contends contract corporation cost Court decedent December 31 deduction deficiency depreciation determined disallowed distribution dividends Docket earnings and profits employees ended January 31 entitled estate tax excess profits tax executors expenses filed FINDINGS OF FACT fiscal year ended follows gift gift tax gross estate gross income Harold Hirsch held Helvering included income tax income tax returns interest Internal Revenue Code issue January 31 liquidation loss ment net income officers opinion paid parties partnership payable payment peti petitioner petitioner's policies principal prior purchase purpose question received renegotiation resident respondent respondent's salaries section 23 section 811 shares statute stipulated stockholders Stralla supra taxable taxpayer thereof tion tioner transfer trust United victory tax Walter Thiele wife
Popular passages
Page 148 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained 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...
Page 300 - The net income shall be computed upon the basis of the taxpayer's annual accounting period (fiscal year or calendar year, as the case may be) in accordance with the method of accounting regularly employed in keeping the books of such taxpayer; but if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income...
Page 170 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not Include 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 552 - Income" Includes gains, profits, and Income derived from salaries, wages, or compensation for personal service • • • of whatever kind and In whatever form paid...
Page 92 - 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 64 - Where property is transferred for less than an adequate and full consideration in money or money's worth, then the amount by which the value of the property exceeded the value of the consideration shall be deemed a gift, and shall be included in computing the amount of gifts made during the calendar year.
Page 773 - Except as provided in section 276 — (a) GENERAL RULE. — The amount of income taxes imposed by this chapter shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period.
Page 951 - Income which Is credited to the account of or set apart for a taxpayer and which may be drawn upon by him at any time is subject to tax for the year during which so credited or set apart, although not then actually reduced to possession.
Page 196 - Is divorced or legally separated, from her husband under a decree of divorce or of separate maintenance, periodic payments (whether or not made at regular Intervals) received subsequent to 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 upon or Incurred by such husband under such decree or under a written Instrument Incident to such divorce or separation...
Page 233 - ... under which he has retained 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...