Reports of the U.S. Board of Tax Appeals, Том 35U.S. Government Printing Office, 1937 |
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Страница 15
... contends , on brief , without the citation of any authority other than the statute itself to sustain such contention , that it is ex- empt from taxation under either or both of subsections ( 1 ) and ( 12 ) of section 103 of the Revenue ...
... contends , on brief , without the citation of any authority other than the statute itself to sustain such contention , that it is ex- empt from taxation under either or both of subsections ( 1 ) and ( 12 ) of section 103 of the Revenue ...
Страница 30
... contend that they are entitled to deduct from their gross incomes of 1932 under section 115 ( c ) of the Revenue Act of ... contends that the loss may not be deducted by reason of the provisions of section 112 ( e ) of the Revenue Act of ...
... contend that they are entitled to deduct from their gross incomes of 1932 under section 115 ( c ) of the Revenue Act of ... contends that the loss may not be deducted by reason of the provisions of section 112 ( e ) of the Revenue Act of ...
Страница 37
... contends that each was a nontaxable exchange . Counsel for the respondent maintains that what was done must be viewed as a single transaction , the substance of which was the transfer by the peti- tioner of only a part of its assets for ...
... contends that each was a nontaxable exchange . Counsel for the respondent maintains that what was done must be viewed as a single transaction , the substance of which was the transfer by the peti- tioner of only a part of its assets for ...
Страница 39
... contends that the petitioner received not only stock of Vacuum , but also the obligation of Vacuum to pay $ 1,312,500 , and that because of the receipt of this obligation the transaction does not come within either subsection ( 3 ) or ...
... contends that the petitioner received not only stock of Vacuum , but also the obligation of Vacuum to pay $ 1,312,500 , and that because of the receipt of this obligation the transaction does not come within either subsection ( 3 ) or ...
Страница 68
... contends , the facts relating to the years 1931 and 1932 are not substantially different from those which obtained ... contending that the petitioner is liable to any deficiencies for the calendar years 1927 , 1928 , and 1929. The ...
... contends , the facts relating to the years 1931 and 1932 are not substantially different from those which obtained ... contending that the petitioner is liable to any deficiencies for the calendar years 1927 , 1928 , and 1929. The ...
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acquired agreement amount assets attorney basis Board bonds California capital stock cash certificates claimed COMMISSIONER OF INTERNAL common stock computing contract cost County Court death decedent decedent's December 31 deduction deficiency Delaware company determined disallowed distributed dividends Docket Donald Symington Dwight Whiting exchange Executors expenses fair market value filed Fisher Body gain or loss Gibson Island gross estate gross income held Helvering included income tax income tax return interest INTERNAL REVENUE Investment issue J. C. Penney January Kirby lease liability liquidation Lumber National Bank net income opinion paid par value parties patents payment percent peti petitioner petitioner's preferred stock prior profits purchase question Rayben Limited real estate received reorganization respondent Revenue Act securities shares of stock sold statute stipulated stockholders supra T. H. Symington taxpayer thereof tion tioner transaction transfer trust trust instrument United wife
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Страница 284 - ... 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...
Страница 388 - If there is distributed, in pursuance of a plan of reorganization, to a shareholder in a corporation a party to the reorganization, stock or securities in such corporation or in another corporation a party to the reorganization...
Страница 284 - ... 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.
Страница 508 - Amounts distributed in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock, and amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the stock.
Страница 29 - If an exchange would be within the provisions of paragraph (3) of sub-division (b) if it were not for the fact that the property received in exchange consists not only of stock or securities permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Страница 275 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Страница 447 - Option with respect to intangible drilling and development costs in general: All expenditures for wages, fuel, repairs, hauling, supplies, etc., incident to and necessary for the drilling of wells and the preparation of wells for the production of oil or gas...
Страница 105 - Any transfer of a material part of his property in the nature of a final disposition or distribution thereof, made by the decedent within two years prior to his death without such consideration, shall, unless shown to the contrary, be deemed to have been made in contemplation of death within the meaning of this title.
Страница 417 - 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.
Страница 57 - Income therefrom) the expenses, losses and other deductions properly *{ portioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be allocated to some item or class of gross income.