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 5
... Rules 213 ( a ) ( 2 ) and 217 ( c ) ( 2 ) ( ii ) , Tax Court Rules of Practice and Procedure , it has the burden of proof on the issue of private inurement . Thayer as president and Mrs. Thayer as vice president together ( 1 ) CHURCH OF ...
... Rules 213 ( a ) ( 2 ) and 217 ( c ) ( 2 ) ( ii ) , Tax Court Rules of Practice and Procedure , it has the burden of proof on the issue of private inurement . Thayer as president and Mrs. Thayer as vice president together ( 1 ) CHURCH OF ...
Page 12
... rules to determine who is taxable on a trust's income , but such rules have no bearing on the deduction issue . Penn v . Commissioner , 51 T.C. 144 , 150 ( 1968 ) ; Lerner v . Commissioner , 71 T.C. 290 , 299 ( 1978 ) . v . Clifford ...
... rules to determine who is taxable on a trust's income , but such rules have no bearing on the deduction issue . Penn v . Commissioner , 51 T.C. 144 , 150 ( 1968 ) ; Lerner v . Commissioner , 71 T.C. 290 , 299 ( 1978 ) . v . Clifford ...
Page 42
... rules of sec . 318 ( a ) ( 3 ) . In partial payment of the redemption price , MDI executed a promissory note to one of the sisters . MDI claimed deductions for accrued interest expenses with regard to the note but did not actually make ...
... rules of sec . 318 ( a ) ( 3 ) . In partial payment of the redemption price , MDI executed a promissory note to one of the sisters . MDI claimed deductions for accrued interest expenses with regard to the note but did not actually make ...
Page 43
... rules of section 3181 so that a redemption by the corporation of stock owned by the trust qualifies as an exchange under section 302 ( b ) ( 1 ) or 302 ( b ) ( 3 ) . ( 2 ) Whether a waiver agreement filed by the trust pursuant to ...
... rules of section 3181 so that a redemption by the corporation of stock owned by the trust qualifies as an exchange under section 302 ( b ) ( 1 ) or 302 ( b ) ( 3 ) . ( 2 ) Whether a waiver agreement filed by the trust pursuant to ...
Page 50
... rules of section 318 shall be applied in determining the ownership of stock for purposes of applying the rules of section 302. Section 318 ( a ) ( 1 ) ( A ) ( ii ) provides , in part , that an individual shall be considered as owning ...
... rules of section 318 shall be applied in determining the ownership of stock for purposes of applying the rules of section 302. Section 318 ( a ) ( 1 ) ( A ) ( ii ) provides , in part , that an individual shall be considered as owning ...
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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...