Reports of the Tax Court of the United States, Volume 54U.S. Government Printing Office, 1970 - Taxation |
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Page 45
... terminated and hence stand dissolved as of the end of business on June 15 , 1965 and Evans agrees that he will convey ... termination date above set forth and agrees that he will , on demand , execute and deliver one or more Powers of ...
... terminated and hence stand dissolved as of the end of business on June 15 , 1965 and Evans agrees that he will convey ... termination date above set forth and agrees that he will , on demand , execute and deliver one or more Powers of ...
Page 48
... terminated . ( b ) TERMINATION.- ( 1 ) GENERAL RULE . - For purposes of subsection ( a ) , a partnership shall be considered as terminated only if— ( A ) no part of any business , financial operation , or venture of the partnership ...
... terminated . ( b ) TERMINATION.- ( 1 ) GENERAL RULE . - For purposes of subsection ( a ) , a partnership shall be considered as terminated only if— ( A ) no part of any business , financial operation , or venture of the partnership ...
Page 50
... terminate the partnership under State law , it is clear that , since the assignment did effect a transfer of 50 percent of the total interest in ... termination of the partnership for Federal tax 50 ( 40 ) 54 UNITED STATES TAX COURT REPORTS.
... terminate the partnership under State law , it is clear that , since the assignment did effect a transfer of 50 percent of the total interest in ... termination of the partnership for Federal tax 50 ( 40 ) 54 UNITED STATES TAX COURT REPORTS.
Page 51
... termination the transferee of the partnership inter- est is to be treated as a partner in a new partnership . ' It follows that the petitioner was , after the assignment , no longer to be regarded as a partner for Federal income tax ...
... termination the transferee of the partnership inter- est is to be treated as a partner in a new partnership . ' It follows that the petitioner was , after the assignment , no longer to be regarded as a partner for Federal income tax ...
Page 86
... termination whether the required employer - employee relationship exists for purposes of the nonstatutory stock option regulations . Perti- nent provisions of the section 31.3401 ( c ) regulations are set forth below : Sec . 31.3401 ( c ) ...
... termination whether the required employer - employee relationship exists for purposes of the nonstatutory stock option regulations . Perti- nent provisions of the section 31.3401 ( c ) regulations are set forth below : Sec . 31.3401 ( c ) ...
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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...