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" In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors... "
Internal Revenue Cumulative Bulletin - Page 524
by United States. Internal Revenue Service - 1981
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1976 - 624 pages
...income for purposes of section 911 and provides, in part, that in the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors, under regulations prescribed by the Secretary or the Secretary's delegate, a reasonable allowance as...
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Reports of the Tax Court of the United States, Volume 51

United States. Tax Court - 1969 - 1116 pages
...services actually rendered." This section further provides that in the case of a taxpayer engaged in a trade or business "in which both personal services...and capital are material income-producing factors," an amount not in excess of 30 percent of the "net profits" of the business shall be considered "earned...
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Internal Revenue Cumulative Bulletin, Issue 2

United States. Internal Revenue Service - 1978 - 630 pages
...received as compensation for personal services actually rendered. In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material incomeproducing factors, a reasonable allowance as compensation for personal services rendered by the taxpayer, not in excess...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1978 - 636 pages
...production of earned income and have not been taken into account in determining the net profits of a trade or business in which both personal services and capital are material income-producing factors (as defined in section 1.1348-3(a)(3)). Deductions properly allocable to or chargeable against earned...
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Internal Revenue Cumulative Bulletin, Issue 2

United States. Internal Revenue Service - 1974 - 624 pages
...received as compensation for personal services actually rendered. In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors, a reasonable allowance as compensation for the personal services rendered by the taxpayer, not in excess...
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Reports of the Tax Court of the United States, Volume 56

United States. Tax Court - 1971 - 1476 pages
...services actually rendered." This section further provides that, in the case of a taxpayer engaged in a trade or business "in which both personal services and capital are material income-producing f actors," an amount not in excess of 30 percent of the "net profits" of the business shall be considered...
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Reports of the United States Tax Court, Volume 71

United States. Tax Court - 1979 - 1248 pages
...as compensation for the personal services actually rendered. In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors, under regulations prescribed by the Secretary or his delegate, a reasonable allowance as compensation...
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Reports of the United States Tax Court, Volume 56

United States. Tax Court - 1971 - 1470 pages
...us compensation for the personal services actually rendered. In the case of a taxpayer engaged In a trade or business In which both personal services and capital are material Income-producing factors, under regulations prescribed by the Secretary or hU delegate, a reasonable allowance as compensation...
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Reports of the United States Tax Court, Volume 92

United States. Tax Court - 1989 - 1448 pages
...as compensation for personal services actually rendered * * * In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors, under regulations prescribed by the Secretary, a reasonable allowance as compensation for the personal...
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Tax Proposals Affecting Private Pension Plans: Hearings Before..., 92-2....

United States. Congress. House. Committee on Ways and Means - 1972 - 924 pages
...as compensation for the personal services actually rendered. In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors, ... a reasonable allowance as compensation for the personal services rendered by the taxpayer, not...
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