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" An amount equal to the portion of the earnings and profits of the taxable year which is required (by a provision of a written contract executed by the corporation prior to May 1, 1936. which provision expressly deals with the disposition of earnings and... "
Cases Decided in the United States Court of Claims - Page 188
by United States. Court of Claims - 1944
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Reports of the U.S. Board of Tax Appeals, Volume 42

United States. Board of Tax Appeals - 1941
...year, pursuant to the provision of a written contract executed by the corporation prior to May 1, 1936, which provision expressly deals with the disposition of earnings and profits of th* taxable year, and that therefore it comes literally within the terms of the statute. The Commissioner...
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Reports of the U.S. Board of Tax Appeals, Volume 45

United States. Board of Tax Appeals - 1942
...is required (by a provision of a written contract executed by the corporation prior to May 1, 1936, which provision expressly deals with the disposition...the taxable year) to be paid within the taxable year for the discharge of a debt, irrevocably set aside within the taxable year for the discharge of a debt...
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Reports of the Tax Court of the United States, Volume 1

United States. Tax Court - 1942
...Is required (by a provision of a written contract executed by the corporation prior to May 1, 1936, which provision expressly deals with the disposition...of a debt ; to the extent that such amount has been so paid or set aside. For the purposes of this paragraph, a requirement to pay or set aside an amount...
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Reports of the Tax Court of the United States, Volume 4

United States. Tax Court - 1944
...prior to May 1, 1936, which provision expressly deali with the disposition of earnings and profits of a taxable year) to be paid within the taxable year In...the taxable year for the discharge of a debt ; to tlie extent that such amount has been so paid or set aside. * * because prior to declaration of...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 317

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1943
...contract must contain a provision requiring that a portion of such earnings and profits either (a) "be paid within the taxable year in discharge of a debt," or (b) "be irrevocably set aside within the taxable year for the discharge of a debt." A taxpayer whose...
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Reports of the Tax Court of the United States, Volume 2

United States. Tax Court - 1944
...is required (by a provision of a written contract executed by the corporation prior to May 1, 1936, which provision expressly deals with the disposition of earnings and profits of the taxable yenr) to be paid within the taxable year in discharge of a debt, or to be irrevocably set aside within...
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Reports of the United States Tax Court, Volume 4

United States. Tax Court - 1945
...Is required (by a provision of a written contract executed by the corporation prior to May 1, 10.16, which provision expressly deals with the disposition of earnings and profits of a taxable year) to be paid within the taxable year in discharge of a debt, or to be irrevocably set...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 326

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1946
...year . . . [are] required (by a provision of a written contract executed by the corporation . . ., which provision expressly deals with the disposition...within the taxable year for the discharge of a debt." (Italics supplied.) Petitioner claimed a credit under 26 (c) (1), but in assessing the deficiency...
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Reports of the Tax Court of the United States, Volume 2

United States. Tax Court - 1943
...a writ* contract executed by the corporation prior to May 1, 3936, which provision expressly Arwith the disposition of earnings and profits of the taxable year) to be paid within * taxable year in discharge of a debt, or to be irrevocably set aside within the taxable T^5? for the...
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Reports of the Tax Court of the United States, Volume 1

United States. Tax Court - 1943
...No part of petitioner's "earnings and profits of the taxable year" is required by a contract "which expressly deals with the disposition of earnings and...within the taxable year for the discharge of a debt ; and no part of such amount of earnings and profits of the taxable year has been so paid or set aside....
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