Reports of the United States Tax Court, Volume 59

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Page 402 - In the case of a series of transactions, the date of the last such transaction) ; and (B) stock of the distributing corporation possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
Page 304 - Except as otherwise provided in this subtitle, gross income means all income from whatever source derived. Including (but not limited to) the following items: (1) Compensation for services, including fees, commissions, and similar items; (2) Gross Income derived from business...
Page 333 - For purposes of paragraph (1), the term "nonbusiness debt" means a debt other than — (A) A debt created or acquired (as the case may be) In connection with a trade or business of the taxpayer; or (B) A debt the loss from the worthlessness of which is incurred In the taxpayer's trade or business.
Page 402 - Amounts distributed in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock, and amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the stock.
Page 428 - The amount of all such items shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under methods of accounting permitted under subdivision (b) of section 212, any such amounts are to be properly accounted for as of a different period...
Page 396 - ... entity fills a useful purpose in business life. Whether the purpose be to gain an advantage under the law of the state of incorporation or to avoid or to comply with the demands of creditors or to serve the creator's personal or undisclosed convenience, so long as that purpose is the equivalent of business activity or is followed by the carrying on of business by the corporation, the corporation remains a separate taxable entity.
Page 311 - Trade or business expenses — (a) In general. There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including — (1) A reasonable allowance for salaries or other compensation for personal services actually rendered...
Page 805 - If a trust is created or property is transferred for both a charitable and a private purpose, deduction may be taken of the value of the charitable beneficial interest only insofar as that interest is presently ascertainable, and hence severable from the noncharitable interest.
Page 792 - General power of appointment The term "general power of appointment" means a power which is exercisable in favor of the decedent, his estate, his creditors, or the creditors of his estate...
Page 87 - States, upon or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of such dividends bears to the amount of such accumulated profits...

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