Reports of the U.S. Board of Tax Appeals, Volume 1U.S. Government Printing Office, 1926 - Taxation |
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Page 11
... debt must have had an existence in fact . A nonexisting debt can not be ascertained to be worthless and charged off to support a deduction from gross income as a bad debt , under section 234 ( a ) ( 5 ) , Revenue Act of 1918 . Submitted ...
... debt must have had an existence in fact . A nonexisting debt can not be ascertained to be worthless and charged off to support a deduction from gross income as a bad debt , under section 234 ( a ) ( 5 ) , Revenue Act of 1918 . Submitted ...
Page 12
... debt had never , at any time , had an existence as a debt to the taxpayer . The facts are fully set forth in the foregoing findings of fact . To entitle a taxpayer to deduct from gross income , as a bad debt , an item ascertained to be ...
... debt had never , at any time , had an existence as a debt to the taxpayer . The facts are fully set forth in the foregoing findings of fact . To entitle a taxpayer to deduct from gross income , as a bad debt , an item ascertained to be ...
Page 15
... debt could not be predicated on the policies of insurance which had been surrendered for cancellation , the certifi- cates of insurance were likewise impotent in this respect . The taxpayer has not shown a debt to have existed from the ...
... debt could not be predicated on the policies of insurance which had been surrendered for cancellation , the certifi- cates of insurance were likewise impotent in this respect . The taxpayer has not shown a debt to have existed from the ...
Page 60
... debts . The parties thereafter stipulated that of $ 21,613.17 bad debts deducted by the partnership and disallowed by the Commissioner , the sum of $ 16,935.27 represented debts ascertained to be worthless and charged off within the ...
... debts . The parties thereafter stipulated that of $ 21,613.17 bad debts deducted by the partnership and disallowed by the Commissioner , the sum of $ 16,935.27 represented debts ascertained to be worthless and charged off within the ...
Page 68
... debt against his creditor without a release of liability , and thereby establish one of the two elements required to perfect an allowable deduction in the income tax return of the creditor . That Mr. Ames did not release the debt is ...
... debt against his creditor without a release of liability , and thereby establish one of the two elements required to perfect an allowable deduction in the income tax return of the creditor . That Mr. Ames did not release the debt is ...
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Common terms and phrases
accrued agreement alleged allowed amount appeal assessment assets Bank Board books of account building calendar capital stock cash cent Central Trust Co charged claimed Coal Commissioner is approved Company computed contract corporation cost debt December 31 decided January DECISION deduction from gross deficiency in tax deficiency letter depreciation determination disallowed discount dividends Docket entitled evidence expenses February 28 filed FINDINGS OF FACT fiscal year ended following FINDINGS GRAUPNER gross income Hartson income and profits income tax income-tax return interest Internal Revenue inventory invested capital issued January 22 January 31 lease liability LITTLETON loss March Nelson net income October 31 opinion paid par value parties partnership patents payer payment period petition preferred stock prior profits taxes purchase question received Revenue Act salary Solicitor of Internal statute STERNHAGEN stockholders tax return taxable taxpayer thereof tion TRUSSELL trust Winthrop Ames
Popular passages
Page 161 - States to divulge or to make known in any manner whatever not provided by law to any person the operations, style of work, or apparatus of any manufacturer or producer visited by him in the discharge of his official duties...
Page 441 - Income may be defined as the gain derived from capital, from labor, or from both combined," provided it be understood to include profit gained through a sale or conversion of capital assets, to which it was applied in the Doyle Case (pp.
Page 471 - ... (1) income accumulated in trust for the benefit of unborn or unascertained persons or persons with contingent interests, and income accumulated or held for future distribution under the terms of the will or trust...
Page 428 - If in the case of any taxpayer, the Commissioner determines that there is a deficiency...
Page 507 - The net income shall be computed upon the basis of the taxpayer's annual accounting period (fiscal year or calendar year, as the case may be) in accordance with the method of accounting regularly employed in keeping the books of such taxpayer; but if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income...
Page 472 - ... there shall be allowed as an additional deduction in computing the net income of the estate or trust the amount of the income of the estate or trust for its taxable year, which is properly paid or credited during such year to any legatee, heir, or beneficiary...
Page 507 - The amount of all such items shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under methods of accounting permitted under subdivision (b) of section 212, any such amounts are to be properly accounted for as of a different period.
Page 338 - A word is not a crystal, transparent and unchanged; it is the skin of a living thought and may vary greatly in color and content according to the circumstances and the time in which it is used.
Page 458 - An amount equal to the value of any property (A) forming a part of the gross estate situated in the United States of any person who died within five years prior to the death of the decedent...
Page 134 - It is essential to just construction that many words which import something excessive should be understood in a more mitigated sense — in that sense which common usage justifies. The word ' necessary