Reports of the Tax Court of the United States, Volume 76U.S. Government Printing Office, 1981 - Taxation |
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Results 1-5 of 100
Page 22
... question of whether the lessee owns the leasehold during the lease term.4 However , the grafting of a judicially originated doctrine onto the jurisprudence of gift - leaseback transactions has complicated the search for a disqualifying ...
... question of whether the lessee owns the leasehold during the lease term.4 However , the grafting of a judicially originated doctrine onto the jurisprudence of gift - leaseback transactions has complicated the search for a disqualifying ...
Page 23
... question of who should be taxed on the trust's income . Second , the property was to revert to the grantor at the end of the trust term . Finally , the trustee was not independent of the grantor . The difficulty in applying such a ...
... question of who should be taxed on the trust's income . Second , the property was to revert to the grantor at the end of the trust term . Finally , the trustee was not independent of the grantor . The difficulty in applying such a ...
Page 31
... question of intent is a question of fact ( Follmer v . Rohrer , 158 Cal . 755 , 112 P. 544 ( Cal . 1910 ) ; Kelly v . Bank of America National Trust & Savings Assn . , 112 Cal . App . 2d 388 , 246 P.2d 92 ( 1952 ) ) , and the holding of ...
... question of intent is a question of fact ( Follmer v . Rohrer , 158 Cal . 755 , 112 P. 544 ( Cal . 1910 ) ; Kelly v . Bank of America National Trust & Savings Assn . , 112 Cal . App . 2d 388 , 246 P.2d 92 ( 1952 ) ) , and the holding of ...
Page 33
... question soluble only by the courts , and attempts by the parties involved ( taxpayers and the Treasury ) to get a judicial resolution of this issue only exacerbates our already burgeoning caseload . Furthermore , it is questionable ...
... question soluble only by the courts , and attempts by the parties involved ( taxpayers and the Treasury ) to get a judicial resolution of this issue only exacerbates our already burgeoning caseload . Furthermore , it is questionable ...
Page 52
... question of whether a distribution , coupled with a redemption , of stock is " essentially equivalent to a dividend . " This is ordinarily a question of fact . United States v . Fewell , 255 F.2d 496 ( 5th Cir . 1958 ) ; Wright v ...
... question of whether a distribution , coupled with a redemption , of stock is " essentially equivalent to a dividend . " This is ordinarily a question of fact . United States v . Fewell , 255 F.2d 496 ( 5th Cir . 1958 ) ; Wright v ...
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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...