Reports of the United States Tax Court, Volume 81 |
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accumulated activities addition agree agreement allowed amended amount apply basis benefits capital claimed Commissioner computed conclude Congress considered contract contributions corporation cost Court decision deduction deficiency determined distribution dividend docket earnings effect election entered entitled escrow established exchange expenses fact Federal filed follows foreign gain gross held holding Hospital included Income Tax Regs individual interest Internal Revenue Internal Revenue Code investment issue Judge lease liability limited loss mailed meaning method notice of deficiency obligation operations opinion paid Panama parties partnership payments percent period petition petitioner petitioner's policies premium present prior production profits purchase pursuant qualify reasonable received record referred regulation renewable reported reserve respect respondent respondent's result royalties Rule shares statement supra taxable taxpayer term tion transaction trust United
Popular passages
Page 744 - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained 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...
Page 120 - If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance, the wife's gross income includes periodic payments (whether or not made at regular intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, in discharge of) a legal obligation which, because of the marital or family relationship, is imposed on or incurred by the husband under the decree or under a written instrument incident...
Page 94 - In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors...
Page 993 - If, however, an intangible asset acquired through capital outlay is known from experience to be of value in the business or in the production of income for only a limited period, the length of which can be estimated from experience with reasonable certainty...
Page 27 - ... means the whole or a part of an agency statement of general or particular applicability and future effect designed to implement, interpret, or prescribe law or policy or describing the organization, procedure, or practice requirements of an agency and includes the approval or prescription for the future of rates, wages, corporate or financial structures or reorganizations thereof, prices, facilities, appliances, services or allowances therefor or of valuations, costs, or accounting, or practices...
Page x - Romeo, and when he shall die, Take him and cut him out in little stars, And he will make the face of heaven so fine, That all the world will be in love with night, And pay no worship to the garish Sun.
Page 467 - Stock owned, directly or indirectly, by or for a corporation, partnership, estate, or trust, shall be considered as being owned proportionately by or for its shareholders, partners, or beneficiaries...
Page 28 - ... (1) a substantive rule which grants or recognizes an exemption or relieves a restriction; (2) interpretative rules and statements of policy; or (3) as otherwise provided by the agency for good cause found and published with the rule.
Page 679 - A limited partner shall not become liable as a general partner unless, in addition to the exercise of his rights and powers as a limited partner, he takes part in the control of the business.
Page 427 - (a) TREATMENT OF TAXES PAID BY FOREIGN CORPORATION. — For purposes of this subpart, a domestic corporation which owns at least 10 percent of the voting stock of a foreign corporation from which it receives dividends in any taxable year shall...