Any earnings or profits accumulated, or increase in value of property accrued, before March 1, 1913, may be distributed exempt from tax, after the earnings and profits accumulated after February 28, 1913, have been distributed... Reports of the U.S. Board of Tax Appeals - Page 682by United States. Board of Tax Appeals - 1934Full view - About this book
| Wisconsin - 1955 - 850 pages
...made. Except as otherwise provided in this chapter, every distribution is made out of earnings and profits to the extent thereof, and from the most recently accumulated earnings and profits. To the extent that any distribution is, under any provision of this chapter, treated as... | |
| United States. Internal Revenue Service - 1962 - 976 pages
...none of the accumulated earnings and profits, or deficits, consist of earnings and profits or deficits accumulated, or increase in value of property accrued, before March 1, 1913. Example (1). (i) X, Y, and Z Corporations make their returns on the basis of the calendar year. On... | |
| United States. Tax Court - 1943 - 1330 pages
...year. (b) SOURCE OP DISTRIBUTIONS. — For the purposes of this chapter every distribution is made out of earnings or profits to the extent thereof, and...distribution shall be applied against and reduce the adjusted basis of the stock provided in section 113. The preceding sentence shall not apply to a distribution... | |
| United States. Tax Court - 1950 - 1144 pages
...its shareholders * * * out of its earnings or profits accumulated after February 28, 1913," and that "any earnings or profits accumulated, or increase...accumulated after February 28, 1913, have been distributed," Congress drew a line at March 1, 1913, not only as to earnings and profits accumulated or existing... | |
| United States. Tax Court - 1945 - 1518 pages
...under section 115 (b) * * * [the distribution of preferred stock] was presumed to have been made "out of earnings or profits to the extent thereof, and...the most recently accumulated earnings or profits." In no sense, therefore, can it be said to have been "held" by Gowran prior to Its declaration. Since... | |
| United States. Tax Court - 1959 - 1470 pages
...Section 115 (b) of the Internal Revenue Code of 1939 provides that "every distribution is made out of earnings or profits to the extent thereof and from the most recently accumulated earnings and profits." At the time of each redemption the corporation had earnings and profits available for... | |
| United States. Internal Revenue Service - 1979 - 644 pages
...provides that, except as otherwise provided in subtitle A, every distribution is made out of earnings and profits to the extent thereof, and from the most recently accumulated earnings and profits. Section 312(e) of the Code provides an exception to section 316 (a). Section 312 (e) provides... | |
| United States. Internal Revenue Service - 1974 - 624 pages
...made. Except as otherwise provided in this subtitle, every distribution is made out of earnings and profits to the extent thereof, and from the most recently accumulated earnings and profits. To the extent that any distribution is, under any provision of this subchapter, treated... | |
| United States. Tax Court - 1971 - 1470 pages
...made. Kxrept as otherwise provided in this subtitle, every distribution Is made nut of earnings and profits to the extent thereof, and from the most recently accumulated earnings and profits. To the extent that any distribution is. under any provision of this subchapter, treated... | |
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