Reports of the Tax Court of the United States, Volume 54U.S. Government Printing Office, 1970 - Taxation |
From inside the book
Results 1-5 of 100
Page 21
... period following the adoption of a plan of complete liquidation , if within that period the corporation distributes its assets in complete liquidation . In the instant case , petitioners adopted plans of complete liquida- tion and ...
... period following the adoption of a plan of complete liquidation , if within that period the corporation distributes its assets in complete liquidation . In the instant case , petitioners adopted plans of complete liquida- tion and ...
Page 88
... period was extended 3 years ( i.e. , to a period of time when the fair market value of the underlying stock was likely to be higher ) and ( 2 ) an option to buy GIAI stock was added . It would be naive to think that these valuable ...
... period was extended 3 years ( i.e. , to a period of time when the fair market value of the underlying stock was likely to be higher ) and ( 2 ) an option to buy GIAI stock was added . It would be naive to think that these valuable ...
Page 90
... period during which petitioner could take advantage of the option price ) and a hedge factor ( the fact that petitioner does not have to risk his capital during the exercise period ) . Included among the factors he examined in valuing ...
... period during which petitioner could take advantage of the option price ) and a hedge factor ( the fact that petitioner does not have to risk his capital during the exercise period ) . Included among the factors he examined in valuing ...
Page 126
... period of separation , and prior to the filing of the petition for divorce , petitioner voluntarily paid his wife $ 650 per month . He also made the mortgage payments on the house she occupied , furnished her an automobile , and paid ...
... period of separation , and prior to the filing of the petition for divorce , petitioner voluntarily paid his wife $ 650 per month . He also made the mortgage payments on the house she occupied , furnished her an automobile , and paid ...
Page 140
... period of 5 years with automatic renewal for successive 5 - year periods unless written notice of termination was given by either party to the other at least 6 months before the end of any period . This franchise agreement was amended ...
... period of 5 years with automatic renewal for successive 5 - year periods unless written notice of termination was given by either party to the other at least 6 months before the end of any period . This franchise agreement was amended ...
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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...