Reports of the U.S. Board of Tax Appeals, Том 35U.S. Government Printing Office, 1937 |
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Страница 10
... losses in Florida , where gambling is prohibited , and had gambling gains in Mexico , may not offset the gains by the losses in computing a net loss . Marshall D. Hall , Esq . , and George M. Thompson , C. P. A. , for the petitioner ...
... losses in Florida , where gambling is prohibited , and had gambling gains in Mexico , may not offset the gains by the losses in computing a net loss . Marshall D. Hall , Esq . , and George M. Thompson , C. P. A. , for the petitioner ...
Страница 11
... losses in 1929 , and the petitioner assails the computation as not truly reflecting his 1929 income or loss . There is no dispute about the facts . The controversy turns upon the proper treatment , as a matter of law , of the Florida ...
... losses in 1929 , and the petitioner assails the computation as not truly reflecting his 1929 income or loss . There is no dispute about the facts . The controversy turns upon the proper treatment , as a matter of law , of the Florida ...
Страница 12
... losses to wipe out his Mexican gains and thus enlarge the 1929 net loss which he may carry over to reduce his 1931 taxable income . Consistently with prior authority , the determination of the respondent must be sustained . Judgment ...
... losses to wipe out his Mexican gains and thus enlarge the 1929 net loss which he may carry over to reduce his 1931 taxable income . Consistently with prior authority , the determination of the respondent must be sustained . Judgment ...
Страница 18
... loss to the part- nership resulting from inventorying the stock at market ; 2. Whether the Commissioner erred in including in the income of the petitioner $ 2,500 representing certain organization expenses of the Home & Foreign ...
... loss to the part- nership resulting from inventorying the stock at market ; 2. Whether the Commissioner erred in including in the income of the petitioner $ 2,500 representing certain organization expenses of the Home & Foreign ...
Страница 20
... loss from its operations for the year 1929 . The petitioner claimed all of the loss of the partnership on his return . The Commissioner , in determining the deficiency , added to the petitioner's income $ 2,500 representing organization ...
... loss from its operations for the year 1929 . The petitioner claimed all of the loss of the partnership on his return . The Commissioner , in determining the deficiency , added to the petitioner's income $ 2,500 representing organization ...
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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.