Reports of the Tax Court of the United States, Volume 54U.S. Government Printing Office, 1970 - Taxation |
From inside the book
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Page 12
... ment to conclude that the Mizners required the Siples to agree to post the collateral as a prerequisite to the purchase of stock . Certainly there is nothing outside the agreement to support such a conclusion . A reasonable assumption ...
... ment to conclude that the Mizners required the Siples to agree to post the collateral as a prerequisite to the purchase of stock . Certainly there is nothing outside the agreement to support such a conclusion . A reasonable assumption ...
Page 31
... ment of the disbursements , and since he was the qualified agent of the petitioner to whom the authority and responsibility had been delegated , it seems that the petitioner must accept the responsibility for the acts of his agent ...
... ment of the disbursements , and since he was the qualified agent of the petitioner to whom the authority and responsibility had been delegated , it seems that the petitioner must accept the responsibility for the acts of his agent ...
Page 45
... ment tax returns reflecting the withholding of taxes , and complied with the depository receipts requirements . By 1965 , relations with Zeier had become so strained that peti- tioner decided that it was time to sever his business ...
... ment tax returns reflecting the withholding of taxes , and complied with the depository receipts requirements . By 1965 , relations with Zeier had become so strained that peti- tioner decided that it was time to sever his business ...
Page 53
... ment Company ) , the members of which firm were engaged in a joint venture . Appellee was required to make such individual return as to each partnership of which he was a member whether or not distribution was made to him , but not if ...
... ment Company ) , the members of which firm were engaged in a joint venture . Appellee was required to make such individual return as to each partnership of which he was a member whether or not distribution was made to him , but not if ...
Page 56
... ment with the depositary , and the amount of the proceeds of any life insurance carried on petitioner's life by Lucey Export Corp. or by Evans and paid or payable to petitioner's estate or to a beneficiary designated by petitioner . It ...
... ment with the depositary , and the amount of the proceeds of any life insurance carried on petitioner's life by Lucey Export Corp. or by Evans and paid or payable to petitioner's estate or to a beneficiary designated by petitioner . It ...
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Common terms and phrases
acquired agreed agreement amount apply assets beneficiary Blairsville carryback cash certiorari Cicio claimed collateral estoppel Commissioner community property contract corporation cost Court Daisy Daisy's death decedent decedent's December 31 decision deduction director of internal distribution distributors district director dividend Dredging Dri-Powr election employees entitled estate tax expenses facts Federal income tax filed follows funds GIAI gift gift tax gross estate gross income held hereinafter Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service issue lease lessee liability liquidation loan loss marital deduction Medco ment MGIC operating option paid parties partnership payment percent peti petitioner petitioner's premium prior purchase purposes pursuant received redemption regulations respect Respondent determined RESPONDENT Docket respondent's September 30 shareholders shares stipulated supra taxable taxpayer testamentary trust tion tioner transaction transfer trust trust instrument United wife
Popular passages
Page 198 - Except as otherwise provided in this contract, any dispute concerning a question of fact arising under this contract which is not disposed of by agreement shall be decided by the Contracting Officer, who shall reduce his decision to writing and mail or otherwise furnish a copy thereof to the Contractor.
Page 301 - Transferred assets — (a) Method of collection. The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, paid, and collected in the same manner and subject to the same provisions and limitations as in the case of the taxes with respect to which the liabilities were incurred: (1) Income, estate, and gift taxes — (A) Transferees.
Page 585 - ... under a decree of divorce or of separate maintenance, the wife's gross Income includes periodic payments (whether or not made at regular intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, in discharge of) a legal obligation which, because of the marital or family relationship, is imposed on or incurred by the husband under the decree or under a written instrument Incident to such divorce or separation.
Page 75 - ... who were shareholders immediately before the transfer), or any combination thereof, is in control of the corporation to which the assets are transferred; but only if, in pursuance of the plan, stock or securities of the corporation to which the assets are transferred are distributed in a transaction which qualifies under section 354, 355, or 356; (E) A recapitalization; or (F) A mere change in identity, form, or place of organization, however effected.
Page 614 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 939 - General rule for methods of accounting — (a) General rule. Taxable income shall be computed under the method of accounting on the basis of which the taxpayer regularly computes his income in keeping his books. (b) Exceptions. If no method of accounting has been regularly used by the taxpayer, or if the method used does not clearly reflect income, the computation of taxable income shall be made under such method as, in the opinion of the Secretary or his delegate, does clearly reflect income.
Page 76 - A transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders immediately before the transfer), or any combination thereof, is in control of the corporation to which the assets are transferred...
Page 585 - Is divorced or legally separated from her husband under a decree of divorce or of separate maintenance...
Page 296 - If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 6 years after the return was filed. For purposes of this subparagraph — (i) In the case of a trade or business, the term "gross income...
Page 837 - ... in discharge of, a legal obligation which, because of the marital or family relationship, is imposed upon or incurred by such husband under such decree or under a written instrument incident to such divorce or separation...