Reports of the Tax Court of the United States, Volume 76U.S. Government Printing Office, 1981 - Taxation |
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Page 79
... loss would be caught in this absolute prohibition . Because such intra - group transfers did not " usually " result in genuine economic realizations of loss , it held that Congress did not deem any of them deductible . W. A. Drake , Inc ...
... loss would be caught in this absolute prohibition . Because such intra - group transfers did not " usually " result in genuine economic realizations of loss , it held that Congress did not deem any of them deductible . W. A. Drake , Inc ...
Page 109
... loss , and $ 1,752.63 was reported as a short - term capital loss . In his notice of deficiency , respon- dent disallowed the claimed capital losses and stated that : ( a ) It is determined that you realized a long - term capital gain ...
... loss , and $ 1,752.63 was reported as a short - term capital loss . In his notice of deficiency , respon- dent disallowed the claimed capital losses and stated that : ( a ) It is determined that you realized a long - term capital gain ...
Page 113
... Loss From EXCHANGES SOLELY IN KIND . --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 ...
... Loss From EXCHANGES SOLELY IN KIND . --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 ...
Page 115
... loss on the exchange of like - kind property is that the taxpayer's economic situation after the exchange is fundamentally the same as it was before the transaction occurred . “ [ I ] f the taxpayer's money is still tied up in the same ...
... loss on the exchange of like - kind property is that the taxpayer's economic situation after the exchange is fundamentally the same as it was before the transaction occurred . “ [ I ] f the taxpayer's money is still tied up in the same ...
Page 202
... losses , which were attributable solely to petitioner's wholly owned subsidiary . Held , inasmuch as that subsidiary was not a member of the group immediately after its organization , the consolidated net operating loss may not be ...
... losses , which were attributable solely to petitioner's wholly owned subsidiary . Held , inasmuch as that subsidiary was not a member of the group immediately after its organization , the consolidated net operating loss may not be ...
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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 contract corporation cost decedent decedent's December 31 decision deduction depreciation distribution 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 mailed McDonald's notice of deficiency 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 shares South Devon cattle statute statutory notice stipulated supra T.C. Memo tax avoidance taxable taxpayer tion trade or business transaction transfer trust United USSD vehicle Western Hockey League
Popular passages
Page 282 - ... 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.
Page 206 - ... (b) Regulations. The Commissioner, with the approval of the Secretary, shall prescribe such regulations as he may deem necessary in order that the tax liability of any affiliated group of corporations making a consolidated return and of each corporation in the group, both during and after the period of affiliation, may be...
Page 410 - Deductions for expenditures for medical care allowable under section 213 will be confined strictly to expenses incurred primarily for the prevention or alleviation of a physical or mental defect or illness.
Page 952 - ... means each separate Interest owned by the taxpayer In each mineral deposit in each separate tract or parcel of land.
Page 135 - ... in any trial, hearing, or other proceeding in or before any court, grand jury, department, officer, agency, regulatory body, legislative committee, or other authority of the United States, a State, or a political subdivision thereof if the disclosure of that information would be in violation of this chapter.
Page 78 - ... the stock owned, directly or indirectly, by or for his partner; (d) The family of an individual shall include only his brothers and sisters (whether by the whole or half blood), spouse, ancestors, and lineal descendants...
Page 436 - (a) REQUIREMENTS FOR QUALIFICATION. — A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
Page 109 - Loss. —The gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis provided in section 1011 for determining gain, and the loss shall be the excess of the adjusted basis provided in such section for determining loss over the amount realized. (b) AMOUNT REALIZED. —The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than...
Page 78 - Stock owned, directly or indirectly, by or for a corporation, partnership, estate, or trust shall be considered as being owned proportionately by its shareholders, partners, or beneficiaries.
Page 77 - Between members of a family, as defined in paragraph (2) (D); (B) Except in the case of distributions in liquidation, between an individual and a corporation more than 50 per centum in value of the outstanding stock of which is owned, directly or Indirectly, by or for such Individual...