Reports of the Tax Court of the United States, Volumen65U.S. Government Printing Office, 1975 |
Dentro del libro
Resultados 1-5 de 100
Página vii
... position , she agreed to pay him in the first years of his services 25 per cent and in later years , including the two taxable years before us , 15 per cent of her earnings in any particular year . Fontaine's compensation was entirely ...
... position , she agreed to pay him in the first years of his services 25 per cent and in later years , including the two taxable years before us , 15 per cent of her earnings in any particular year . Fontaine's compensation was entirely ...
Página 5
... position , respondent cites several cases in which he contends that a trade or business was found to exist where there was no showing of an offering of goods or services to others . Thus , in Paul J. O'Connell , T.C. Memo . 1974- 128 ...
... position , respondent cites several cases in which he contends that a trade or business was found to exist where there was no showing of an offering of goods or services to others . Thus , in Paul J. O'Connell , T.C. Memo . 1974- 128 ...
Página 7
... position that petitioner realized a long - term capital gain of $ 565,115 upon the disposition of its option . Based on this position respondent determined a deficiency in petitioner's Federal income tax and an addition thereto under ...
... position that petitioner realized a long - term capital gain of $ 565,115 upon the disposition of its option . Based on this position respondent determined a deficiency in petitioner's Federal income tax and an addition thereto under ...
Página 13
... position that petitioner disposed of its option and received the exchange property in return . Respondent alleges that this transaction does not qualify under the provisions of section 1031 and that petitioner has recognized a long ...
... position that petitioner disposed of its option and received the exchange property in return . Respondent alleges that this transaction does not qualify under the provisions of section 1031 and that petitioner has recognized a long ...
Página 14
... position . Rule 142 ( a ) , Tax Court Rules of Practice and Procedure . Respondent's primary argument is that we should view this transaction in its entirety and not consider its individual , component steps . However we have been ...
... position . Rule 142 ( a ) , Tax Court Rules of Practice and Procedure . Respondent's primary argument is that we should view this transaction in its entirety and not consider its individual , component steps . However we have been ...
Otras ediciones - Ver todas
Reports of the Tax Court of the United States, Volumen108 United States. Tax Court Vista completa - 1997 |
Reports of the Tax Court of the United States, Volumen7 United States. Tax Court Vista completa - 1947 |
Reports of the Tax Court of the United States, Volumen118 United States. Tax Court Vista completa - 2002 |
Términos y frases comunes
2d Cir 5th Cir affd agreement allowed amended amount applied assets basis beneficiaries carryback cash claim computed Congress corporation CR trusts Crow-Burlingame death decedent decedent's December 31 depreciation distribution Easy Rider election entitled escrow estate tax expenses fact Federal income tax filed gift tax gross income held hereinafter Hotel Florence included Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service investment credit issue lease liability liquidation loan loss marital deduction Nor-West notice of deficiency operating opinion ordinary income ownership paid parties partnership payments percent petition petitioner petitioner's postmark prior purchase purposes pursuant received regulations Rept respect Respondent determined RESPONDENT Docket respondent's rule section 38 property shareholders shares spouse statute statutory subsidiary supra Tax Court tax return taxable income taxpayer termination trade or business transaction transfer trust instrument United usufruct
Pasajes populares
Página 257 - The following acts or any of them, are crimes coming within the jurisdiction of the Tribunal for which there shall be individual responsibility: "(a) Crimes Against Peace: namely, planning, preparation, initiation or waging of a war of aggression, or a war in violation of international treaties, agreements or assurances, or participation in a common plan or conspiracy for the accomplishment of any of the foregoing.
Página 189 - For purposes of the tax imposed by section 2001, the value of the taxable estate shall, except as limited by subsections (b), (c), and (d), be determined by deducting from the value of the gross estate an amount equal to the value of any interest in property which passes or has passed from the decedent to his surviving spouse, but only to the extent that such interest is included in determining the value of the gross estate.
Página 132 - Future interests" is a legal term, and includes reversions, remainders, and other interests or estates, whether vested or contingent, and whether or not supported by a particular interest or estate, which are limited to commence in use, possession or enjoyment at some future date or time.
Página 487 - That the value of foreign coin as expressed in the money of account of the United States shall be that of the pure metal of such coin of standard value ; and the values of the standard coins in circulation of the various nations of the world shall be estimated annually by the Director of the Mint, and be proclaimed on the first day of January by the Secretary of the Treasury.
Página 719 - No Act of Congress shall be construed to invalidate, impair. or supersede any law enacted by any State for the purpose of regulating the business of insurance...
Página 789 - ... through the ownership, directly or Indirectly, of 50 percent or more of the total combined voting power of all classes of stock entitled to vote or 50 percent or more of the total value of shares of all classes of stock of the corporation.
Página 206 - partnership" includes a syndicate group, pool, joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title, a trust or estate or a corporation; and the term "partner" includes a member in such a syndicate, group, pool, joint venture, or organization.
Página 258 - Leaders, organizers, instigators and accomplices participating in the formulation or execution of a common plan or conspiracy to commit any of the foregoing crimes are responsible for all acts performed by any persons in execution of such plan.
Página 1007 - It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails or of any facility of any national securities exchange, "(a) To employ any device, scheme, or artifice to defraud...
Página 1023 - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...