Reports of the Tax Court of the United States, Volume 67U.S. Government Printing Office, 1977 - Taxation |
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Page 25
... meaning , and this meaning is clearly explained in the Senate committee report . Secondly , it would be odd ( and again inconsistent ) to exclude a use - restricted transfer from a transfer of a portion of all substantial rights if the ...
... meaning , and this meaning is clearly explained in the Senate committee report . Secondly , it would be odd ( and again inconsistent ) to exclude a use - restricted transfer from a transfer of a portion of all substantial rights if the ...
Page 37
... meaning as it does in sec . 1.1502-25 , Income Tax Regs . , relating to the computa- tion of the consolidated deduction under sec . 922 , I.R.C. 1954 . Held , further , this Court did not abuse its discretion in denying a motion for ...
... meaning as it does in sec . 1.1502-25 , Income Tax Regs . , relating to the computa- tion of the consolidated deduction under sec . 922 , I.R.C. 1954 . Held , further , this Court did not abuse its discretion in denying a motion for ...
Page 42
... meaning of the phrase " portion of the consolidated taxable income attributable to such [ WHTC ] corporations " as used in section 1503 ( b ) ( 1 ) ( A ) and ( B ) . Respondent contends that the phrase refers to a fraction of the ...
... meaning of the phrase " portion of the consolidated taxable income attributable to such [ WHTC ] corporations " as used in section 1503 ( b ) ( 1 ) ( A ) and ( B ) . Respondent contends that the phrase refers to a fraction of the ...
Page 46
... meaning in both calculations . To compute the section 922 deduction by using one WHTC income figure and then to turn around and compute the upper and lower limits of the credit - limiting " notch " created by section 1503 ( b ) ( 1 ) by ...
... meaning in both calculations . To compute the section 922 deduction by using one WHTC income figure and then to turn around and compute the upper and lower limits of the credit - limiting " notch " created by section 1503 ( b ) ( 1 ) by ...
Page 49
... meaning of section 809 ( d ) ( 5 ) , ' thereby entitling petitioner to the 3 - percent deduction for premiums provided in such section and ( 2 ) if not , whether petitioner is entitled to the 2 - percent deduction for such contracts as ...
... meaning of section 809 ( d ) ( 5 ) , ' thereby entitling petitioner to the 3 - percent deduction for premiums provided in such section and ( 2 ) if not , whether petitioner is entitled to the 2 - percent deduction for such contracts as ...
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Common terms and phrases
5th Cir affd agreement allocated amended amount applicable Assemblies of God assets basis Camous claimed compensation computation contract Corp cost decedent decedent's December December 16 deduction depreciation disallowed distribution dividend earnings and profits employees entitled estate tax facts Federal income tax filed Frick Building funds gift tax gross income Harder Tree held hereinafter included Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service issue Las Vegas lease liability Nevada test site notice of deficiency October 31 opinion option paid parties partnership payments percent period petition petitioner petitioner's prior purchase purposes pursuant received redemption REECO resided respect Respondent determined RESPONDENT Docket respondent's Rule September 30 shareholders shares spouse statute statutory stipulated subsidiary supra Tax Court taxable income taxable year ended taxable years 1970 taxpayer tion transaction transfer trust United Webb WHTCs
Popular passages
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 490 - IB for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary...
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.