Reports of the United States Tax Court, Volume 71 |
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Page 2
m the estatuilly stipulated herein OPINION TIETJENS , Judge : Respondent
determined deficiencies in petitioners ' Federal income taxes in the amounts of $
18 , 349 . 85 for 1971 and $ 2 , 164 . 44 for 1972 . After certain concessions , the ...
m the estatuilly stipulated herein OPINION TIETJENS , Judge : Respondent
determined deficiencies in petitioners ' Federal income taxes in the amounts of $
18 , 349 . 85 for 1971 and $ 2 , 164 . 44 for 1972 . After certain concessions , the ...
Page 11
The estate deducted the liabilities involved from its gross estate under section
2053 ( a ) in computing its Federal estate tax and would again be using those
payments , through a basis increase , for the Federal income tax benefit of
petitioner .
The estate deducted the liabilities involved from its gross estate under section
2053 ( a ) in computing its Federal estate tax and would again be using those
payments , through a basis increase , for the Federal income tax benefit of
petitioner .
Page 13
See generally R . Stephens , G . Maxfield & S . Lind , Federal Estate and Gift
Taxation , pp . 5 - 12 ( 3d ed . 1974 ) ; M . Ferguson , J . Freeland & R . Stephens ,
Federal Income Taxation of Estates and Beneficiaries , p . 320 ( 1970 ) . Thus in ...
See generally R . Stephens , G . Maxfield & S . Lind , Federal Estate and Gift
Taxation , pp . 5 - 12 ( 3d ed . 1974 ) ; M . Ferguson , J . Freeland & R . Stephens ,
Federal Income Taxation of Estates and Beneficiaries , p . 320 ( 1970 ) . Thus in ...
Page 31
... instant case , when that rationale is recast in light of the present state of the law
of Federal estate taxation and the context of the facts found in the instant case .
The other case cited by the majority on the section 2042 ( 1 ) point , Freedman v .
... instant case , when that rationale is recast in light of the present state of the law
of Federal estate taxation and the context of the facts found in the instant case .
The other case cited by the majority on the section 2042 ( 1 ) point , Freedman v .
Page 55
FEATHERSTON , Judge : In this case , respondent determined deficiencies in
petitioners ' Federal income tax for the years 1972 , 1973 , and 1974 , as follows :
Petitioners 1972 1973 1974 Carl E . Koch and Paula Koch . . . . . . . $ 24 , 601 .
FEATHERSTON , Judge : In this case , respondent determined deficiencies in
petitioners ' Federal income tax for the years 1972 , 1973 , and 1974 , as follows :
Petitioners 1972 1973 1974 Carl E . Koch and Paula Koch . . . . . . . $ 24 , 601 .
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acquired activities addition agree agreement allowed amount application argues assets basis benefit capital charitable claimed Code Commissioner considered contract contributions corporation cost Court decedent decedent's December decision deduction deficiency determined distribution dividend earnings easements educational effect employee ending entitled exchange exempt exercise expenses facts Federal filed funds further gain gift gross held holding hospital included Income Tax Income Tax Regs individual interest Internal Revenue Internal Revenue Code inventory investment issue lease liabilities limited loss meaning Natural operated opinion organization paid parties partnership payments percent period petitioner petitioner's prior purchase qualified reasonable received record reference regulations respect respondent respondent's result rule securities shareholders shares sold statute substantial supra taxable taxpayer term trade transaction transfer trust United
Popular passages
Page 121 - ... organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or...
Page 429 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 308 - BASIS. (a) DEALERS IN PERSONAL PROPERTY. — Under regulations prescribed by the Commissioner with the approval of the Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the gross profit realized or to be realized when payment is completed, bears to the total contract price.
Page 112 - If, on a motion asserting the defense numbered (6) to dismiss for failure of the pleading to state a claim upon which relief can be granted, matters outside the pleading are presented to and not excluded by the court, the motion shall be treated as one for summary judgment and disposed of as provided in Rule 56, and all parties shall be given reasonable opportunity to present all material made pertinent to such a motion by Rule 56.
Page 262 - It is a familiar rule that a thing may be within the letter of the statute and yet not within the statute, because not within its spirit, nor within the intention of its makers.
Page 734 - ... the acquisition by one corporation, in exchange solely for all or a part of its voting stock...
Page 557 - A husband and wife cannot, by any contract with each other, alter their legal relations, except as to property, and except that they may agree, in writing, to an immediate separation, and may make provision for the support of either of them and of their children during such separation.
Page 144 - The value of the gross estate shall include the value of all property to the extent of the interest therein of the decedent at the time of his death.
Page 462 - (a) GENERAL RULE. — In the case of an individual, there shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the sum of — "(1) the qualified energy conservation expenditures, plus " (2) the qualified renewable energy source expenditures, "(b) QUALIFIED EXPENDITURES.
Page 63 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind...
Bibliographic information
| Title | Reports of the United States Tax Court, Volume 71 |
| Author | United States. Tax Court |
| Publisher | The Court, 1979 |
| Original from | the University of Michigan |
| Digitized | 9 May 2007 |
| Export Citation | BiBTeX EndNote RefMan |