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 96
Page 39
... earnings tax on a determination that the corporation was " formed or availed of the purpose of avoiding the income tax with respect to its shareholders or the shareholders of any other corporation . " Sec . 1551 disallows the corporate ...
... earnings tax on a determination that the corporation was " formed or availed of the purpose of avoiding the income tax with respect to its shareholders or the shareholders of any other corporation . " Sec . 1551 disallows the corporate ...
Page 50
... earnings consti- tuted community property of both of them under the law of that State . The annual accounting period of petitioners as well as that of Richard and Maxine was the calendar year . During each of the years 1961 , 1963 , and ...
... earnings consti- tuted community property of both of them under the law of that State . The annual accounting period of petitioners as well as that of Richard and Maxine was the calendar year . During each of the years 1961 , 1963 , and ...
Page 51
... earnings within the statutory period would not deprive her father - in- law of the right to deduct the earnings thus accrued . But Maxine was not an employee , and her earnings are not involved herein . Of course , as a consequence of ...
... earnings within the statutory period would not deprive her father - in- law of the right to deduct the earnings thus accrued . But Maxine was not an employee , and her earnings are not involved herein . Of course , as a consequence of ...
Page 52
... earnings regardless of his wife's com- munity interest therein . Further , the wife herself would have no right to bring any action demanding payment of those earnings , for it appears to be well established that it is the husband who ...
... earnings regardless of his wife's com- munity interest therein . Further , the wife herself would have no right to bring any action demanding payment of those earnings , for it appears to be well established that it is the husband who ...
Page 53
... earnings has resulted in a variety of decisions affecting their tax liabilities . But in general , a common thread runs through these decisions , namely , an effort by the courts to interpret the various statu- tory provisions in such ...
... earnings has resulted in a variety of decisions affecting their tax liabilities . But in general , a common thread runs through these decisions , namely , an effort by the courts to interpret the various statu- tory provisions in such ...
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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.