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" 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,... "
Federal Income, Estate and Gift Tax Laws, Correlated - Page 314
by United States, Walter Elbert Barton - 1944 - 1242 pages
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Reports of the United States Tax Court, Volume 32

United States. Tax Court - 1960
...or dairy purposes, and held by him for 12 months or more from the date of acquisition. (2) GHNERAL RULE. If, during the taxable year, the recognized...or exchanges of capital assets. For the purposes of lliis paragraph : (A) In determining under this paragraph whether gains exceed losses, the gains and...
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Internal Revenue Code of 1954, as Amended and in Force on January 3, 1961

United States, United States. Congress. Joint Committee on Internal Revenue Taxation - 1961 - 1148 pages
...INVOLUNTARY CONVERSIONS. (a) GENERAL RULE. If, during the taxable year, the recognized gains on after December 31, 1 purposes of this subsection (1) in determining under this subsection whether gains exceed losses,...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 364

United States. Supreme Court - 1961
...by the taxpayer primarily for sale to customers in the ordinary course of his trade or business .... "(2) General rule. "If, during the taxable year, the...or exchanges of capital assets held for more than 6 months. . . ." 130 Opinion of the Court. The Tax Court, adopting its opinion in Midwest Motor Express,...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 364

United States. Supreme Court - 1961
...by the taxpayer primarily for sale to customers in the ordinary course of his trade or business .... "(2) General rule. "If, during the taxable year, the...or exchanges of capital assets held for more than 6 months. . . ." COMMISSIONER v. GILLETTE MOTOR CO. 133 130 Opinion of the Court. The Tax Court, adopting...
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Reports of the Tax Court of the United States, Volume 33

United States. Tax Court - 1961
...INVOLUNTARY CONVERSIONS. (a) OENEBAL RULE. If, during the taxable year, the recognized gains on sales or exchanges of property used In the trade or...or exchanges of capital assets held for more than 0 months. If such gains do not exceed such losses, such gains and losses shall not be considered as...
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Tax Cases Decided with Opinions by the Supreme Court of the United States

Congress. Internal Revenue Taxation Joint Committee - 1961
...General rule. "If, during the taxable year, the recognized gains upon sales or exchanges of property nsed in the trade or business, plus the recognized gains...or exchanges of capital assets held for more than 6 months . . ." within the capital-gains provisions of the Internal Revenue Code. Rather, it is necessary...
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Reports of the Tax Court of the United States, Volume 33

United States. Tax Court - 1961
...year, the recognized gains upon sales or exchanges of property used In the trade or business * * * exceed the recognized losses from such sales, exchanges,...months. If such gains do not exceed such losses, such trains and losses shall not be considered as gains and losses from sales or exchanges of capital assets....
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Cases Decided in the United States Court of Claims ... with ..., Volumes 140-150

United States. Court of Claims, Audrey Bernhardt - 1962
...to recover some or all of the taxes previously paid for those years. 572 Opinion of tha Court ceed the recognized losses from such sales, exchanges,...considered as gains and losses from sales or exchanges of capital assets. * * * Plaintiffs say that American sold its stock in the Detroit Edison Company...
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Cases Decided in the United States Court of Claims ... with ..., Volume 153

United States. Court of Claims, Audrey Bernhardt - 1963
...taxpayer primarily for sale to customers in the ordinary course of his trade or business, * * *. (j) (2) If, during the taxable year, the recognized gains...or exchanges of capital assets held for more than 6 months. * * * In order for the plaintiff to come within the provisions of section 117(j) the burden...
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Reports of the Tax Court of the United States, Volume 44

United States. Tax Court - 1965
...provided in part as follows : (a) GENERAL RULE. If, during the taxable year, the recognized gains on sales or exchanges of property used In the trade or...losses from sales or exchanges of capital assets. For purposes of this subsection (2) losses upon the destruction, In whole or...
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