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 11
... reasonable interpretation of the petitioners ' agreement with the Mizners would seem to be that the petitioners desired to limit their capital investment in King's Beach to the equity and direct loan com- mitments which were ...
... reasonable interpretation of the petitioners ' agreement with the Mizners would seem to be that the petitioners desired to limit their capital investment in King's Beach to the equity and direct loan com- mitments which were ...
Page 40
... reasonable manner . " United States v . Correll , 389 U.S. 299 , 307 ( 1967 ) . Therefore , unless respondent's regulations are " unreasonable and plainly inconsistent with the revenue statutes " they must be sustained . Bingler v ...
... reasonable manner . " United States v . Correll , 389 U.S. 299 , 307 ( 1967 ) . Therefore , unless respondent's regulations are " unreasonable and plainly inconsistent with the revenue statutes " they must be sustained . Bingler v ...
Page 47
... reasonable compensation for services rendered to the partnership by the donor , and except to the extent that the portion of such share attributable to donated capital is proportionately greater than the share of the donor attributable ...
... reasonable compensation for services rendered to the partnership by the donor , and except to the extent that the portion of such share attributable to donated capital is proportionately greater than the share of the donor attributable ...
Page 89
... reasonable accuracy , which requires that the taxpayer be able to show that all of the following conditions exist : ( a ) The option is freely transferable by the optionee ; ( b ) The option is exercisable immediately in full by the ...
... reasonable accuracy , which requires that the taxpayer be able to show that all of the following conditions exist : ( a ) The option is freely transferable by the optionee ; ( b ) The option is exercisable immediately in full by the ...
Page 91
... reasonable accuracy at the time of their grant on September 2 , 1958. Lorie stressed the difficulty of determining the fair market value of the stock based upon the few isolated transactions between third parties . Other elements ...
... reasonable accuracy at the time of their grant on September 2 , 1958. Lorie stressed the difficulty of determining the fair market value of the stock based upon the few isolated transactions between third parties . Other elements ...
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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.