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addition agreement allowed amended amount applicable assets Associates basis capital claimed clear Code Commissioner compensation computation considered constitute contends contract controlled corporation cost Court December decision deduction deficiency depreciation determined distribution dividend docket earnings and profits effect employees ended entitled evidence exercise expenses facts filed follows funds further gross income held hold included income tax income tax returns interest Internal Revenue Internal Revenue Code involved issue joint lease liability limited loss meaning method notice operations opinion option paid parent parties payments percent period petition petitioner petitioner's portion position prior purchase qualified question reason received record referred regulations reported resided respect respondent respondent's result Rule securities shareholders shares subsidiary supra Tax Regs taxable taxpayer tion transfer trust United
Page 978 - ... owned or controlled directly or indirectly by the same interests, the Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 672 - Court pursuant to statutory authority, the privilege of a witness, person, government, State, or political subdivision thereof shall be governed by the principles of the common law as they may be interpreted by the courts of the United States in the light of reason and experience.
Page 187 - Except as provided in section 276 — (a) GENERAL RULE. — The amount of income taxes imposed by this title shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period.
Page 217 - A court of the United States shall have power to punish by fine or imprisonment, at its discretion, such contempt of its authority, and none other, as — "(1) Misbehavior of any person in its presence or so near thereto as to obstruct the administration of justice; "(2) Misbehavior of any of its officers in their official transactions; "(3) Disobedience or resistance to its lawful writ, process, order, rule, decree, or command.
Page 168 - 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 386 - Deductions otherwise allowed by law not attributable to the operation of a trade or business regularly carried on by the taxpayer...
Page xxv - Trade or business expenses — (a) In general. There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business...
Page 132 - ... (4) if the contributions or benefits provided under the plan do not discriminate in favor of employees who are officers, shareholders, persons whose principal duties consist in supervising the work of other employees, or highly compensated employees.
Page 100 - There shall be allowed as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear (including a reasonable allowance for obsolescence) — (!) of property used in the trade or business, or (2) of property held for the production of income.