Reports of the United States Tax Court, Volume 59United States Tax Court, 1972 - Government publications |
From inside the book
Results 1-5 of 100
Page 1
... remaining for decision is whether Asheville Hosiery Co. was prevented by either section 382 or section 2691 from deducting prior period net operating losses during the years in issue . 1 All statutory references are to the Internal ...
... remaining for decision is whether Asheville Hosiery Co. was prevented by either section 382 or section 2691 from deducting prior period net operating losses during the years in issue . 1 All statutory references are to the Internal ...
Page 36
... remaining amount due , which included both principal and interest or premium . It necessarily follows that the security for the repayment of " cost " was at all times more than adequate . As distinguished from the obligations in the ...
... remaining amount due , which included both principal and interest or premium . It necessarily follows that the security for the repayment of " cost " was at all times more than adequate . As distinguished from the obligations in the ...
Page 38
... remaining issues for our decision are : ( 1 ) Whether amounts paid by petitioner corporation to Raymond Nicoll as compen- sation in the taxable year April 1 , 1965 , to December 31 , 1965 , and the taxable years 1966 and 1967 , in ...
... remaining issues for our decision are : ( 1 ) Whether amounts paid by petitioner corporation to Raymond Nicoll as compen- sation in the taxable year April 1 , 1965 , to December 31 , 1965 , and the taxable years 1966 and 1967 , in ...
Page 44
... remaining for our decision . The first issue in- volves the reasonableness of compensation paid by R. J. Nicoll Co. to Raymond in the years 1965 , 1966 , and 1967. The second issue involves the deductibility by the corporation of ...
... remaining for our decision . The first issue in- volves the reasonableness of compensation paid by R. J. Nicoll Co. to Raymond in the years 1965 , 1966 , and 1967. The second issue involves the deductibility by the corporation of ...
Page 49
... remaining secretarial functions and " ran er- rands " for Raymond as needed in the business . As Raymond himself performed little , if any of these administrative tasks , we cannot at- tribute any significant portion of his compensation ...
... remaining secretarial functions and " ran er- rands " for Raymond as needed in the business . As Raymond himself performed little , if any of these administrative tasks , we cannot at- tribute any significant portion of his compensation ...
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Common terms and phrases
accumulated profits agreement amount Asheville assets basis Candy Spots cash certiorari claimed collateral estoppel Commissioner compensation computation controlled foreign corporation corporation's Court debt decedent decedent's December 31 deduction distribution dividend earnings and profits employees entitled estate tax expenses facts fair market value Federal income tax filed foreign personal holding foreign tax foreign tax credit Glen Raven greenhouses gross income held hereinafter included Income Tax Regs income tax return indebtedness interest Internal Revenue Code issue July 31 Kitro lease liability liquidation loan ment mortgage motel NAFCO notice of deficiency operating loss paid Palpar parties partnership payment percent personal holding company peti petitioner petitioner's preferred stock prior purchase purposes pursuant received rental Rept respect Respondent determined respondent's Robertson Holdings shareholders shares statute statutory stipulated stock options supra syndication taxable income taxable year ended taxpayer tion tioner transaction transfer trust United
Popular passages
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...