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. |
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Page 36
... fact that it was done . Cf. U.S. Trust Co. v . Commissioner , supra . We conclude , therefore , that by each " Declaration of Trust " the gran- tors intended to create , and in fact created , two separate trusts . The second issue for ...
... fact that it was done . Cf. U.S. Trust Co. v . Commissioner , supra . We conclude , therefore , that by each " Declaration of Trust " the gran- tors intended to create , and in fact created , two separate trusts . The second issue for ...
Page 44
... fact administered as one trust . Similarly , in Sence , the Court of Claims expressly reserved the tax- avoidance question which we face here since it was able to find that the 19 trusts were in fact administered as one . As the court ...
... fact administered as one trust . Similarly , in Sence , the Court of Claims expressly reserved the tax- avoidance question which we face here since it was able to find that the 19 trusts were in fact administered as one . As the court ...
Page 45
... fact that the Supreme Court , in a case decided less than 3 years after Gregory v . Helvering , supra , held that amendments to a trust instru- ment were effective to create three separate taxable entities despite an express finding by ...
... fact that the Supreme Court , in a case decided less than 3 years after Gregory v . Helvering , supra , held that amendments to a trust instru- ment were effective to create three separate taxable entities despite an express finding by ...
Page 79
... facts disclose that petitioner purchased the Rudolph assets , not to acquire the underly- ing land but rather to ... fact that petitioner was willing to pay Rudolph its adjusted basis of the assets acquired in no way forecloses our ...
... facts disclose that petitioner purchased the Rudolph assets , not to acquire the underly- ing land but rather to ... fact that petitioner was willing to pay Rudolph its adjusted basis of the assets acquired in no way forecloses our ...
Page 80
... fact is of no assistance to petitioner for two reasons . First , petitioner has failed to prove that the determination , though made subsequent to Novem- ber 8 , 1961 , was made subsequent to the date of sale , November 30 , 1961 ...
... fact is of no assistance to petitioner for two reasons . First , petitioner has failed to prove that the determination , though made subsequent to Novem- ber 8 , 1961 , was made subsequent to the date of sale , November 30 , 1961 ...
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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.