Reports of the Tax Court of the United States, Volume 51U.S. Government Printing Office, 1969 - Law reports, digests, etc Final issue of each volume includes table of cases reported in the volume. |
From inside the book
Results 1-5 of 100
Page 4
... COMMISSIONER'S ALLOCATION OF 1963 PAYMENT Child support .. Alimony and temporary support .. Interest ... Other ( nondeductible ) . 1961 judgment after child- support credit of $ 4,755 Balance left in 1963 after Commissioner's allocation ...
... COMMISSIONER'S ALLOCATION OF 1963 PAYMENT Child support .. Alimony and temporary support .. Interest ... Other ( nondeductible ) . 1961 judgment after child- support credit of $ 4,755 Balance left in 1963 after Commissioner's allocation ...
Page 35
... Commissioner , supra ; McHarg v . Fitzpatrick , 210 F. 2d 792 ( C.A. 2 , 1954 ) ; Commissioner v . McIlvaine , 78 F. 2d 787 ( C.A. 7 , 1935 ) , affd . 296 U.S. 488 ( 1936 ) ; State Sav . Loan & Trust Co. v . Commissioner , 63 F. 2d 482 ...
... Commissioner , supra ; McHarg v . Fitzpatrick , 210 F. 2d 792 ( C.A. 2 , 1954 ) ; Commissioner v . McIlvaine , 78 F. 2d 787 ( C.A. 7 , 1935 ) , affd . 296 U.S. 488 ( 1936 ) ; State Sav . Loan & Trust Co. v . Commissioner , 63 F. 2d 482 ...
Page 36
... Commissioner , 143 F. 2d 43 , 46 ( C.A. 7 , 1944 ) , affirming 1 T.C. 590 ( 1943 ) ; Estate of Marvin L. Pardee , 49 T.C. 140 , 148 ( 1967 ) . While this may have been done to avoid taxes , it by no means alters the fact that it was ...
... Commissioner , 143 F. 2d 43 , 46 ( C.A. 7 , 1944 ) , affirming 1 T.C. 590 ( 1943 ) ; Estate of Marvin L. Pardee , 49 T.C. 140 , 148 ( 1967 ) . While this may have been done to avoid taxes , it by no means alters the fact that it was ...
Page 39
... Commissioner , 323 F. 2d 316 ( C.A. 9 , 1963 ) ; and Weller v . Commissioner , 270 F. 2d 294 ( C.A. 3 , 1959 ) , respondent characterizes these trusts as shams lacking business purpose , which , apart from the anticipated tax benefit ...
... Commissioner , 323 F. 2d 316 ( C.A. 9 , 1963 ) ; and Weller v . Commissioner , 270 F. 2d 294 ( C.A. 3 , 1959 ) , respondent characterizes these trusts as shams lacking business purpose , which , apart from the anticipated tax benefit ...
Page 44
... Commissioner v . Tower , 327 U.S. 280 ( 1946 ) ; Commis- sioner v . Culbertson , 337 U.S. 733 , 744 fn . 13 ( 1949 ) . Corporations are not invalidated if the creator's aim is tax reduction , but are recognized for tax purposes if they ...
... Commissioner v . Tower , 327 U.S. 280 ( 1946 ) ; Commis- sioner v . Culbertson , 337 U.S. 733 , 744 fn . 13 ( 1949 ) . Corporations are not invalidated if the creator's aim is tax reduction , but are recognized for tax purposes if they ...
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Common terms and phrases
agreement allowed amount apply assets bank basis beneficiaries bromine capital certiorari claimed community property computed contends contract corporation cost Court decedent decedent's December December 31 deduction depreciation disallowed distribution district director Dorman Mills earnings employees entitled Estelle Morris expenditures expenses Federal income tax filed gift gift tax gross income held hereinafter Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service issue Itmann lease liability loan loss magnesium hydroxide ment notice of deficiency Nutrilite Oak Park operating paid Panfield parties partnership payment percent period peti petition petitioner petitioner's Pocahontas premiums prior profits purchase purpose received referred regulations renegotiable rental respect Respondent determined RESPONDENT Docket respondent's Settlor shares statutory stipulated supra Suzanne McConnell taxable income taxpayer Temco Throndson tion tioner trade or business transaction transfer trust wife
Popular passages
Page 368 - For purposes of the tax Imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate...
Page 112 - medical care" means amounts paid — (A) for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including...
Page 166 - There shall be allowed as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear (including a reasonable allowance for obsolescence) — ( 1 ) Of property used In the trade or business, or (2) Of property held for the production of Income.
Page 570 - An organization operated for the primary purpose of carrying on a trade or business for profit...
Page 630 - Any amount received — (A) As a scholarship at an educational institution...
Page 186 - The tax shall apply whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible...
Page 470 - One year after the close of the first taxable year in which any part of the gain upon the conversion Is realized...
Page 752 - In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors...
Page 652 - If, however, an intangible asset acquired through capital outlay is known from experience to be of value in the business or in the production of income for only a limited period, the length of which can be estimated from experience with reasonable certainty, such intangible asset may be the subject of a depreciation allowance, provided the facts are fully shown in the return or prior thereto to the satisfaction of the Commissioner.
Page 281 - To constitute a bona fide sale for an adequate and full consideration in money or money's worth, the transfer must have been made in good faith, and the price must have been an adequate and full equivalent reducible to a money value.