Reports of the Tax Court of the United States, Volume 72U.S. Government Printing Office, 1979 - Taxation |
From inside the book
Results 1-5 of 100
Page 19
... percent of $ 7 million , respondent would give petitioner a cost basis in the system hardware of 3.87 percent of $ 5,050,000 or $ 195,000 . 6 Petitioner claims a fair market value as of November 1 , 1972 , for the ranch of $ 4,333,000 ...
... percent of $ 7 million , respondent would give petitioner a cost basis in the system hardware of 3.87 percent of $ 5,050,000 or $ 195,000 . 6 Petitioner claims a fair market value as of November 1 , 1972 , for the ranch of $ 4,333,000 ...
Page 53
... percent for the period of its fiscal year prior to Jan. 1 , 1971 , and 30 percent for the period after Dec. 31 , 1970 , of its net long - term capital gains . To the extent petitioner can reduce its long- term capital gains without ...
... percent for the period of its fiscal year prior to Jan. 1 , 1971 , and 30 percent for the period after Dec. 31 , 1970 , of its net long - term capital gains . To the extent petitioner can reduce its long- term capital gains without ...
Page 82
... percent excise tax under section 4941 ( b ) ( 1 ) for the same acts of self - dealing . However , because of the wording of the statute under which the 200 - percent tax is imposed , a serious question was raised as to the authority of ...
... percent excise tax under section 4941 ( b ) ( 1 ) for the same acts of self - dealing . However , because of the wording of the statute under which the 200 - percent tax is imposed , a serious question was raised as to the authority of ...
Page 121
... percent limitation for the petitioner's contribution deduc- tion under section 404 ( a ) ( 3 ) ( A ) . The four employees had $ 897.72 allocated to their accounts , which was forfeited to the remaining participants in the plan . For the ...
... percent limitation for the petitioner's contribution deduc- tion under section 404 ( a ) ( 3 ) ( A ) . The four employees had $ 897.72 allocated to their accounts , which was forfeited to the remaining participants in the plan . For the ...
Page 123
... percent of compensation paid or accrued during the taxable year " to all employees under the * plan . " Respondent contends that , in determining the 15- percent limitation on deductible contributions , petitioner should not have ...
... percent of compensation paid or accrued during the taxable year " to all employees under the * plan . " Respondent contends that , in determining the 15- percent limitation on deductible contributions , petitioner should not have ...
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Common terms and phrases
5th Cir activity affd agreement allocation amended amount applied assets Axelrod Bardahl basis benefit cash claimed coal contract contracts for deed corporation cost decedent decedent's December 31 decision deduction distribution dividend earnings employees estate tax exempt expenditures expenses facts fair market value Farms Federal income tax filed gross income held horses Income Tax Regs income tax returns incurred interest Internal Revenue Code Internal Revenue Service inventory investment issue joint venture Judge KLAS-TV Larchmont lease liability LIFO loan loss method of accounting notice of deficiency OLINV operation opinion ordinary income paid parties partner partnership payment percent petition petitioner petitioner's prior profit purchase purposes pursuant ranch reasonable received relay rail Rept respect Respondent determined RESPONDENT Docket respondent's Rocco self-dealing statute statutory stipulated subrogation subsidiaries supra taxable income taxpayer tion trade or business transaction transfer trust Turkey U.S. dollars United
Popular passages
Page 553 - That whenever in the opinion of the Commissioner the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income.
Page 563 - partnership" Includes a syndicate, group, pool. Joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which Is not, within the meaning of this title, a trust or estate or a corporation; and the term "partner" includes a member In such a syndicate, group, pool.
Page 519 - ... personal holding company income as defined in section 543, and if at any time during the last half of the taxable year more than 50 percent in value of its outstanding stock is owned, directly or indirectly, by or for not more than five individuals. (Sections 541-547.) Foreign personal holding companies. — Section 551 (a) requires that the undistributed foreign personal holding company...
Page 305 - ... (c) Guaranteed payments. To the extent determined without regard to the income of the partnership, payments to a partner for services or the use of capital shall be considered as made to one who is not a member of the partnership, but only for the purposes of section 61 (a) (relating to gross income) and section 162 (a) (relating to trade or business expenses).
Page 890 - Secretary or his delegate that such transfer was not In pursuance of a plan having as one of Its principal purposes the avoidance of Federal Income taxes.
Page 86 - ... recovery exclusion", with respect to a bad debt, prior tax, or delinquency amount, means the amount, determined in accordance with regulations prescribed by the Secretary or his delegate, of the deductions or credits allowed, on account of such bad debt, prior tax, or delinquency amount, which did not result In a reduction of the taxpayer's tax under this...
Page 349 - In the case of an individual, all the ordinary and necessary expenses paid or incurred during the taxable year for the production or collection of income, or for the management, conservation, or maintenance of property held for the production of income.
Page 737 - ... ordinary and necessary expenses paid or incurred in carrying on a trade or business.
Page 771 - A statutory discrimination will not be set aside if any state of facts reasonably may be conceived to justify it.
Page 85 - This paragraph shall not apply to a disposition to an organization (other than a cooperative described in section 521) which is exempt from the tax imposed by this chapter.