Reports of the United States Tax Court, Volume 54United States Tax Court, 1970 - Government publications Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
From inside the book
Results 1-5 of 100
Page 2
... additional financing . The Mizners approached petitioners concerning a possible advance to the corporation . After an extended period of discussion it was orally agreed that petitioners would purchase a number of shares from King's ...
... additional financing . The Mizners approached petitioners concerning a possible advance to the corporation . After an extended period of discussion it was orally agreed that petitioners would purchase a number of shares from King's ...
Page 3
... addition , the agreement went on to state that , within 30 days after King's Beach notified petitioners that the ... additional 1,281 shares for $ 50,000 . This money was to be used in the same fashion as the $ 100,000 . Following ...
... addition , the agreement went on to state that , within 30 days after King's Beach notified petitioners that the ... additional 1,281 shares for $ 50,000 . This money was to be used in the same fashion as the $ 100,000 . Following ...
Page 4
... additional costs were due to design changes , one of which expanded the number of bowling lanes from 12 to 16 . On June 17 , 1960 , 1 petitioners , the Mizners , and King's Beach en- tered into a " Supplementary Agreement , " which due ...
... additional costs were due to design changes , one of which expanded the number of bowling lanes from 12 to 16 . On June 17 , 1960 , 1 petitioners , the Mizners , and King's Beach en- tered into a " Supplementary Agreement , " which due ...
Page 71
... additional stock would have been meaningless , and they do not contend that the failure to issue any such additional stock would render sec . 368 ( a ) ( 1 ) ( D ) inapplicable . Indeed it has already been well established that no such ...
... additional stock would have been meaningless , and they do not contend that the failure to issue any such additional stock would render sec . 368 ( a ) ( 1 ) ( D ) inapplicable . Indeed it has already been well established that no such ...
Page 110
... additional 5 percent for each additional month or fraction thereof during which such failure continues , not exceeding 25 percent in the aggregate . The maximum 25 - percent addition to tax has been asserted for each of the years 1954 ...
... additional 5 percent for each additional month or fraction thereof during which such failure continues , not exceeding 25 percent in the aggregate . The maximum 25 - percent addition to tax has been asserted for each of the years 1954 ...
Other editions - View all
Common terms and phrases
acquired 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 dolomitic 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 423 - If an exchange would be within the provisions of subsection (b) (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 191 - 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 467 - If a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income which he is required to return, even though it may still be claimed that he is not entitled to retain the money, and even though he may still be adjudged liable to restore its equivalent.
Page 387 - Rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity.
Page 570 - If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance...
Page 110 - ... filing), unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the amount required to be shown as tax on such return 5 percent of the amount of such tax if the failure is for not more than 1 month, with an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate.
Page 573 - ... the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Page 574 - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
Page 206 - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death(1) The possession or enjoyment of, or the right to the income from, the property, or (2) The right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom.
Page 756 - STOCK (a) GENERAL RULE. — If a corporation redeems its stock (within the meaning of section 317(b)), and if paragraph (1), (2), (3), or (4) of subsection (b) applies, such redemption shall be treated as a distribution in part or full payment in exchange for the stock. (b) REDEMPTIONS TREATED AS EXCHANGES. — (1) REDEMPTIONS NOT EQUIVALENT TO DIVIDENDS. — Subsection (a) shall apply if the redemption is not essentially equivalent to a dividend.