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" capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer... "
Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924 - Page 301
by United States. Internal Revenue Service - 1924 - 363 pages
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Tax Treatment of Thrift Partnership: Joint Hearing Before the Subcommittee ...

United States. Congress. Senate. Committee on Finance. Subcommittee on Taxation and Debt Management - 1982 - 174 pages
...would not be capital assets. Code S 1221(1) provides that the term "capital asset" does not include "stock in trade of the taxpayer or other property...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business ...". As a result, any gain or...
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A Guide to Federal Income Tax for Timber Owners

1982 - 84 pages
...the taxpayer (whether or not connected with his trade or business), but does not include — ( 1 ) stock in trade of the taxpayer or other property of...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business; (2) property, used in his trade...
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Replacement of domestic international sales corporations (DISCs ...

United States. Congress. Joint Committee on Taxation - 1983 - 68 pages
...indebtedness arising out of the disposition of property described in section 1221(1) (which includes stock in trade of the taxpayer or other property of...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business), or the performance of services,...
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Foreign Sales Corporation Act: hearings before the Committee on Finance ...

United States. Congress. Senate. Committee on Finance - 1984 - 396 pages
...indebtedness arising out of the disposition of property described in section 1221(1) (which includes stock in trade of the taxpayer or other property of...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business), or the performance of services,...
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Federal Taxation of S Corporations

Deborah H. Schenk - 2017 - 858 pages
...1362(d)(3)(C)(ii): 26 LI.SC § l362(d)(3)(C)(ii). Inventory is defined in IRC § 1221(1), 26 USC § 1221(1) as "stock in trade of the taxpayer or other property...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business." "* Treas. Reg. § 1.1362-2(c)(5)(ii)(D)(2);...
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Federal Taxation of Real Estate

Allan J. Samansky, James Charles Smith - 1985 - 840 pages
...five state exceptions.30 For real estate the two most important exceptions are the following: "(1) stock in trade of the taxpayer or other property of...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business; "(2) property, used in his trade...
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Rent-to-own: Providing Opportunities Or Gouging Consumers ..., Volume 4

United States. Congress. House. Committee on Banking, Finance, and Urban Affairs - 1993 - 1012 pages
...held by the taxpayer (whether or not connected with his trade or business) , but does not include (1) stock in trade of the taxpayer or other property of...taxable year or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business; IRC 1221 (1992). Section 79-32,...
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Study of the Overall State of the Federal Tax System and Recommendations for ...

United States. Congress. Joint Committee on Taxation - 2001 - 620 pages
...property held by the taxpayer other than certain listed exceptions. A principal exception applies to "stock in trade of the taxpayer or other property...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business."58 This exception is intended...
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Practical Guide to Mergers, Acquisitions and Business Sales

Joseph B. Darby - 2006 - 542 pages
...generating ordinary income on sale, include the following (enumerated to conform to Code Sec. 1221 (a)): (1) stock in trade of the taxpayer or other property of...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business;4 (2) property, used in his trade...
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Income Tax Regulations, As of January 2008

CCH Tax Law Editors - 2008 - 2242 pages
...Regardless of use in an active trade or business, section 367(a)(l) shall apply to the transfer of — (1) Stock in trade of the taxpayer or other property of...taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of its trade or business; and (2) A copyright, a literary,...
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