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" ... rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity... "
Federal Income and Estate Tax Laws: Correlated and Annotated, Being a ... - Page 94
by Walter Elbert Barton, United States, Carroll Wright Browning - 1925 - 549 pages
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 356

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1958 - 884 pages
...ordinary and necessary business expense.2 This seems to us to be recognition of a required to be made as a condition to the continued use or possession, for...is not taking title or in which he has no equity." 53 Stat. 12, as amended, 56 Stat. 819, 26 USC §23(a)(l)(A). 2 111. Rev. Stat., 1945, c. 38, § 336....
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Tax Cases Decided with Opinions by the Supreme Court of the United States

Congress. Internal Revenue Taxation Joint Committee - 1959 - 220 pages
...for personal services actually rendered; . . . and rentals or other payments required to be made as a condition to the continued use or possession, for...is not taking title or in which he has no equity." 53 Stat. 12, as amended, 56 Stat. 819, 26 USO § 23 (a) (1) (A). 1 111. Rev. Stat., 1945, c. 38, §...
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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 - 1208 pages
...home in the pursuit of a trade or business; and (3) rentals or other payments required to be made as a perty or stock acquired before the disposition of the converted 162(a For purposes of the preceding sentence, the place of residence of a Member of Congress (including...
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Compilation of the Social Security Laws

United States. Congress. House. Committee on Ways and Means - 1961 - 520 pages
...in the pursuit of a trade or business ; and (3) rentals or other payments required to be made as a condition to the continued use or possession, for...is not taking title or in which he has no equity. For purposes of the preceding sentence, the place of residence of a Member of Congress (including any...
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Legislative History of the Internal Revenue Code of 1954 ..., Volumes 8-11

Floyd Morse Hubbard, United States. Congress. Joint Committee on Internal Revenue Taxation - 1967 - 1392 pages
...in tho pursuit of a trade or business; and "(3) rentals or other payments required to be made as a condition to the continued use or possession, for...is not taking title or in which he has no equity. CH. IB, PT. VI — DEDUCTIONS — EXPENSES (in part) iredesignaled, added) SEC. 162— Continued (a)...
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Reports of the Tax Court of the United States, Volume 45

United States. Tax Court - 1966 - 656 pages
...trade or business, including — »**•*•• (3) rentals or other payments required to be made as a condition to the continued use or possession, for...is not taking title or in which he has no equity. The question of whether the payments were actually rentals is a question of fact to be determined in...
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Reports of the Tax Court of the United States, Volume 34

United States. Tax Court - 1961 - 1226 pages
...be allowed as •le-dactions the ordinary and necessary expenses In carrying on a trade or business, •-Including • • • rentals or other payments...purposes of the trade or business, of property to which tbe taxpayer has not taken or Is not taking title or In which he has no equity." 11 Section 23 (a)...
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Reports of the United States Tax Court, Volume 66

United States. Tax Court - 1976 - 1190 pages
...on any trade or business, including— * * * (3) rentals or other payments required to be made as a condition to the continued use or possession, for...is not taking title or in which he has no equity. We believe the key to defining Conso's rental liability is in turn determined by examining the relationship...
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Reports of the United States Tax Court, Volume 63

United States. Tax Court - 1974 - 862 pages
...on any trade or business, including — * * * (3) rentals or other payments required to be made as a condition to the continued use or possession, for...is not taking title or in which he has no equity. As noted previously, petitioner was not compelled to enter into the agreement. It did so because it...
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Reports of the United States Tax Court, Volume 67

United States. Tax Court - 1977 - 1160 pages
...business including: (3) rentals or other payments required to be made as a condition to the continued possession, for purposes of the trade or business,...is not taking title or in which he has no equity. As in the case of salary or compensation, section 162(a)(3) does not specifically limit deductions...
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