Reports of the U.S. Board of Tax Appeals, Том 35U.S. Government Printing Office, 1937 |
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Страница liii
... Transfer & Terminal Warehouse Co. , 27 B. T. A. 651 .. 297 Dallas Transfer & Terminal Warehouse Co. v . Commissioner , 70 Fed . ( 2d ) 95 .... 298 Dalton v . Bowers , 56 Fed . ( 2d ) 16 ; 287 U. S. 404 . 130 Daniel Brothers Co. v ...
... Transfer & Terminal Warehouse Co. , 27 B. T. A. 651 .. 297 Dallas Transfer & Terminal Warehouse Co. v . Commissioner , 70 Fed . ( 2d ) 95 .... 298 Dalton v . Bowers , 56 Fed . ( 2d ) 16 ; 287 U. S. 404 . 130 Daniel Brothers Co. v ...
Страница 9
... transfer of the debt was , in fact , and we have so held , a transfer of nothing . It was in- tended to be and was an effective charge - off of the bad debt by Mac- donald Engineering Co. of California . Respondent contends ...
... transfer of the debt was , in fact , and we have so held , a transfer of nothing . It was in- tended to be and was an effective charge - off of the bad debt by Mac- donald Engineering Co. of California . Respondent contends ...
Страница 24
... transfer by way of dividend , she sought to bring about a " reorganization . " She caused the Averill Corporation to be organized . United then transferred to Averill the 1,000 shares of Monitors stock , for which all of the shares of ...
... transfer by way of dividend , she sought to bring about a " reorganization . " She caused the Averill Corporation to be organized . United then transferred to Averill the 1,000 shares of Monitors stock , for which all of the shares of ...
Страница 36
... transferred the remain- ing 26,250 shares ( 75 percent ) of the new company's stock to the Vacuum Oil Co. Under the ... transfer by petitioner of 26,250 shares of stock of the new corporation to Vacuum was a sale resulting in taxable ...
... transferred the remain- ing 26,250 shares ( 75 percent ) of the new company's stock to the Vacuum Oil Co. Under the ... transfer by petitioner of 26,250 shares of stock of the new corporation to Vacuum was a sale resulting in taxable ...
Страница 38
... transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred ...
... transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred ...
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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.