Reports of the Tax Court of the United States, Volume 72U.S. Government Printing Office, 1979 - Taxation |
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Page xiii
... Prior to his service on that Court he was an Assistant Attorney General of Iowa , and before that time he was in private practice there . He assumed senior status at the Tax Court in the late 1960's and continued to serve at the Court ...
... Prior to his service on that Court he was an Assistant Attorney General of Iowa , and before that time he was in private practice there . He assumed senior status at the Tax Court in the late 1960's and continued to serve at the Court ...
Page 40
... prior to the enactment of subsection 152 ( e ) and that the interpretation of the sentence in the separation agreement should take into account this sequence of events . Prior to the enactment of subsection 152 ( e ) , the general rule ...
... prior to the enactment of subsection 152 ( e ) and that the interpretation of the sentence in the separation agreement should take into account this sequence of events . Prior to the enactment of subsection 152 ( e ) , the general rule ...
Page 68
... prior year , and ( b ) any net operating loss from a prior taxable year which is carried to such taxable year but which does not reduce taxable income ( computed without regard to the deduction under section 172 ( a ) ) in such taxable ...
... prior year , and ( b ) any net operating loss from a prior taxable year which is carried to such taxable year but which does not reduce taxable income ( computed without regard to the deduction under section 172 ( a ) ) in such taxable ...
Page 83
... Prior to 1970 , compliance with this latter prohibition was insured , at least in part , by section 503 which imposed arm's - length standards of conduct on dealings between a private foundation and its founders and major contributors ...
... Prior to 1970 , compliance with this latter prohibition was insured , at least in part , by section 503 which imposed arm's - length standards of conduct on dealings between a private foundation and its founders and major contributors ...
Page 89
... prior to the entry of a decision with respect to the first- and second - level taxes , the steps necessary to correct could be stipulated by the parties at a hearing under Rule 155 , Tax Court Rules of Practice and Procedure . If the ...
... prior to the entry of a decision with respect to the first- and second - level taxes , the steps necessary to correct could be stipulated by the parties at a hearing under Rule 155 , Tax Court Rules of Practice and Procedure . If the ...
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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.