Reports of the United States Tax Court, Volume 76United States Tax Court, 1981 - Government publications |
From inside the book
Results 1-5 of 100
Page 8
... Internal Revenue Code of 1954.1 FINDINGS OF FACT Some of the facts have been stipulated , and those facts are so found . The petitioners , Lewis H. V. and Nancy C. May , husband and wife , maintained their legal residence in Arcadia ...
... Internal Revenue Code of 1954.1 FINDINGS OF FACT Some of the facts have been stipulated , and those facts are so found . The petitioners , Lewis H. V. and Nancy C. May , husband and wife , maintained their legal residence in Arcadia ...
Page 56
United States. Tax Court. The attribution rules of section 318 came into the tax law with the enactment of the Internal Revenue Code of 1954. Their legislative history provides an illuminating background for our examination . In the ...
United States. Tax Court. The attribution rules of section 318 came into the tax law with the enactment of the Internal Revenue Code of 1954. Their legislative history provides an illuminating background for our examination . In the ...
Page 58
... Internal Revenue Code of 1954 , wrote a summary of its follow - up work for the period 1956-58 wherein it stated ... Revenue Code , " 72 Harv . L. Rev. 209-210 ( 1958 ) : " These rules of constructive ownership rest on certain ...
... Internal Revenue Code of 1954 , wrote a summary of its follow - up work for the period 1956-58 wherein it stated ... Revenue Code , " 72 Harv . L. Rev. 209-210 ( 1958 ) : " These rules of constructive ownership rest on certain ...
Page 71
... Internal Revenue Code . 24 Section 302 ( c ) ( 2 ) ( A ) states , in part , “ In the case of a distribution described in subsection ( b ) ( 3 ) , section 318 ( a ) ( 1 ) shall not apply if * " The Fifth Circuit has rewritten that ...
... Internal Revenue Code . 24 Section 302 ( c ) ( 2 ) ( A ) states , in part , “ In the case of a distribution described in subsection ( b ) ( 3 ) , section 318 ( a ) ( 1 ) shall not apply if * " The Fifth Circuit has rewritten that ...
Page 77
... Internal Revenue Code , 72 Harv . L. Rev. 209 ( 1958 ) ; B. Randall & K. Benson , " Family Dissension and the Attribution Rules of Sections 267 , 318 , and 544 " 53 Taxes 534 ( 1975 ) . * H . Rept . 1546 , 75th Cong . , 1st Sess ...
... Internal Revenue Code , 72 Harv . L. Rev. 209 ( 1958 ) ; B. Randall & K. Benson , " Family Dissension and the Attribution Rules of Sections 267 , 318 , and 544 " 53 Taxes 534 ( 1975 ) . * H . Rept . 1546 , 75th Cong . , 1st Sess ...
Other editions - View all
Common terms and phrases
5th Cir affd agreed agreement allocation allowed alumina amended amount apply assets beneficiaries Big Beef claim Club collateral estoppel Comalco compensation contends contract corporation cost decedent decedent's December 31 decision depreciation dividend Dutch elm disease employees entitled expenses facts Federal income tax fees filed gross income held hockey Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service inventory investment issue lease LIFO limited partnership loss notice of deficiency oil and gas operating opinion paid parties partners payment percent percentage depletion petition petitioner petitioner's Player prior production purchase purposes pursuant qualify reasonable received regulations Rept respect RESPONDENT Docket respondent's Seattle Totems South Devon cattle statute stipulated supra T.C. Memo tax avoidance taxable taxpayer tion trade or business transaction transfer trust United USSD vehicle Western Hockey League Whispering Hills
Popular passages
Page 593 - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...
Page 826 - See section 179 and § 1.179-1 for a further description of the term "reasonable allowance." (b) Useful life. For the purpose of section 167 the estimated useful life of an asset is not necessarily the useful life inherent in the asset but is the period over which the asset may reasonably be expected to be useful to the taxpayer in his trade or business or in the production of his income.
Page 449 - MAINTENANCE.—If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance, the wife's gross income includes periodic payments (whether or not made at regular intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, in discharge of) a legal obligation which, because of the marital or family relationship, is imposed on or incurred by the husband under the decree or under a written instrument...
Page 778 - ... (3) Certain tax-free transactions. If the basis of property in the hands of a transferee Is determined by reference to its basis in the hands of the transferor by reason of the application of section 332...
Page 1008 - 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 to be held either for productive use in trade or business or for investment.
Page 1134 - In any proceeding before the Tax Court involving a notice of deficiency based in whole or in part on the allegation that all or any part of the earnings and profits have been permitted to accumulate beyond the reasonable needs of the business...
Page 355 - There shall be allowed as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear (including a reasonable allowance for obsolescence) — ( 1 ) Of property used In the trade or business, or (2) Of property held for the production of Income.
Page 898 - ... gross income from the property excluding from such gross income an amount equal to any rents or royalties paid or incurred by the taxpayer in respect of the property. Such allowance shall not exceed 50 percent of the taxpayer's taxable income from the property (computed without allowance for depletion).
Page 939 - If in the case of any taxpayer, the Commissioner determines that there is a deficiency in respect of the tax imposed by this title, the Commissioner is authorized to send notice of such deficiency to the taxpayer by registered mail.
Page 278 - ... there shall be included in the gross income an amount which bears the same relation to the total compensation as the number of days of performance of the labor or services within the United States bears to the total number of days of performance of labor or services for which the payment is made.