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able accumulation adjusted basis agreement allocable allowed amount annuity apply assets Assume attributable beginning beneficiary capital carried chapter charitable Code computed considered contracts contributions corpus death decedent December deduction deemed defined depreciation determined distributable net income distributive share dividends effect election equal example exceeds excess exchange excluded expenses extent filed gain grantor graph gross income illustrated included insurance company interest Internal Internal Revenue Code investment less liability limited loss means ment method mutual nership obligation operations owner paid paragraph partner partnership payment percent period person policyholders portion preceding premiums prior reason received reduced regulations relating reserves respect rule section 691 separate share ship specified Statutory provisions subparagraph taken tax imposed tax-exempt taxable income term termination tion transfer treated tributed trust trust instrument
Page 212 - ... (2) General rule. — If, during the taxable year, the recognized gains upon sales or exchanges of property used in the trade or business, plus the recognized gains from the compulsory or involuntary conversion (as a result of destruction in whole or in part, theft or seizure, or an exercise of the power of requisition or condemnation or the threat or imminence thereof...
Page 18 - Income, without limitation, which pursuant to the terms of the governing Instrument is, during the taxable year, paid or permanently set aside for a purpose specified In section 170 (c), or Is to be used exclusively for religious, charitable, scientific, literary, or educational purposes, or for the prevention of cruelty to children or animals, or for the establishment, acquisition, maintenance or operation of a public cemetery not operated for profit.
Page 349 - Gross Income" means the sum of (A) the combined gross amount earned during the taxable year, from investment Income and from underwriting income as provided in this subsection, computed on the basis of the underwriting and investment exhibit of the annual statement approved by the National Convention of Insurance Commissioners...
Page 96 - ... such creator or person through the ownership, directly or indirectly, of 50 percent or more of the total combined voting power of all classes of stock entitled to vote or 50 percent or more of the total value of shares of all classes of stock of the corporation.
Page 119 - The character of any item of income, gain, loss, deduction, or credit included in a partner's distributive share under paragraphs (1) through (8) of subsection (a) shall be determined as if such item were realized directly from the source from which realized by the partnership, or incurred in the same manner as incurred by the partnership.
Page 103 - ... (B) the person who, by reason of the death of the decedent, acquires the right to receive the amount, if the right to receive the amount is not acquired by the decedent's estate from the decedent; or (C) the person who acquires from the decedent the right to receive the amount by bequest, devise, or inheritance, if the amount is received after a distribution by the decedent's estate of such right.
Page 191 - For purposes of this part, the term 'life insurance reserves' means amounts — "(A) which are computed or estimated on the basis of recognized mortality or morbidity tables and assumed rates of interest, and "(B) which are set aside to mature or liquidate, either by payment or reinsurance, future unaccrued claims arising from life insurance, annuity, and noncancellable health and accident insurance contracts (including life insurance or annuity contracts combined with noncancellable health and accident...
Page 128 - In the case of any partnership interest created by gift, the distributive share of the donee under the partnership agreement shall be includible in his gross income, except to the extent that such share is determined without allowance of reasonable compensation for services rendered to the partnership by the donor, and except to the extent that the portion of such share attributable to donated capital is proportionately greater than the share of the donor attributable to the donor's capital.
Page 201 - Life insurance companies issuing policies covering life, health, and accident insurance combined in one policy issued on the weekly premium payment plan, continuing for life and not subject to cancellation...
Page 141 - For purposes of subsection (a), a partnership shall be considered as terminated only if — (A) No part of any business, financial operation, or venture of the partnership continues to be carried on by any of its partners In a partnership, or (B) Within a 12-month period there Is a sale or exchange of 50 percent or more of the total interest in partnership capital and profits.