 | United States. Internal Revenue Service - 1976 - 612 pages
...respect to such profits or income by any foreign country or by any possession of the United States. The Secretary shall have full power to determine from...dividends were paid, treating dividends paid in the first 60 days of any year as having been paid from the accumulated profits of the preceding year or years... | |
 | United States. Internal Revenue Service - 1974 - 624 pages
...filed the income tax return of the domestic shareholder claiming a credit under section 902 of the Code shall have full power to determine from the accumulated...years such dividends were paid, treating dividends as having been paid from the most recently accumulated gains, profits, or earnings. Section 1.902-3(c)... | |
 | United States. Tax Court - 1962 - 1268 pages
...that where the dividend is paid within 60 days from the close of the taxable year it shall be treated as having been paid from the accumulated profits of the preceding year or years, it logically follows that the reference to most recently accumulated gains, profits, or earnings in... | |
 | 1969 - 548 pages
...accumulated profits of what year or years such dividends were paid, treating dividends paid In the first 60 days of any year as having been paid from the accumulated profits of t be preceding year or years (unless to bis satisfaction shown otherwise), and In other respects treating... | |
 | United States. Tax Court - 1991 - 968 pages
...respect to such profits or income by any foreign country or by any possession of the United States. The Secretary shall have full power to determine from...dividends were paid, treating dividends paid in the first 60 days of any year as having been paid from the accumulated profits of the preceding year or 'years... | |
 | United States. Tax Court - 1972 - 942 pages
...(c) APPLICABLE RULES. — (1) ACCUMULATED PROFITS DEFINED. — » * * The Secretary or his delegate shall have full power to determine from the accumulated...dividends were paid, treating dividends paid in the first 60 days of any year as having been paid) from the accumulated profits of the preceding year or years... | |
 | United States. Tax Court - 1984 - 1120 pages
...Rul. 69-447, 1969-2 CB 153. In that ruling, pursuant to the authority granted him under sec. 902(c) to "determine from the accumulated profits of what year or years such dividends were paid," the Commissioner concluded that "any dividends paid after the first 60 days of the taxable year are... | |
 | United States. Tax Court - 1973 - 912 pages
...excess profits taxes imposed on or with respect to such profits or income. The Secretary or his delegate shall have full power to determine from the accumulated...dividends were paid, treating dividends paid in the first 60 days of any year as having been paid from the accumulated profits of the preceding year or years... | |
 | United States - 1976 - 424 pages
...respect to such profits or income by any foreign country or by any possession of the United States. The Secretary shall have full power to determine from...dividends were paid, treating dividends paid in the first 60 days of any year as having been paid from the accumulated profits of the preceding year or years... | |
 | 1972 - 580 pages
...return of the taxpayer claiming a credit by virtue of the provisions of section 902 shall have the power to determine from the accumulated profits of what year or years the dividends received were paid. In making such determination, any dividends which are paid to the... | |
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In the first sixty days of any year as having been paid from the accumulated profits of the preceding year or years (unless to his satisfaction shown otherwise), and in other respects treating dividends as having been paid from the most recently accumulated... 
