Reports of the United States Tax Court, Volume 81United States Tax Court, 1984 - Government publications |
From inside the book
Results 1-5 of 94
Page 72
... earnings and profits in excess of $ 100,000 . In their 1977 returns , Kirby and Marvin each treated the $ 50,000 distribution from E - B Grain as distributions of previ- ously taxed income pursuant to section 1375 ( d ) 72 ( 70 ) 81 ...
... earnings and profits in excess of $ 100,000 . In their 1977 returns , Kirby and Marvin each treated the $ 50,000 distribution from E - B Grain as distributions of previ- ously taxed income pursuant to section 1375 ( d ) 72 ( 70 ) 81 ...
Page 73
... earnings and profits of the corporation shall not be reduced by reason of such distribution . Section 7503 provides in pertinent part : When the last day prescribed under authority of the internal revenue laws for performing any act ...
... earnings and profits of the corporation shall not be reduced by reason of such distribution . Section 7503 provides in pertinent part : When the last day prescribed under authority of the internal revenue laws for performing any act ...
Page 93
... earnings of $ 196,046 from a business in which he engaged in the fabrication and sale of ornamental ironworks . He contends that capital was not a " material income - producing factor " in his business , within the meaning of section ...
... earnings of $ 196,046 from a business in which he engaged in the fabrication and sale of ornamental ironworks . He contends that capital was not a " material income - producing factor " in his business , within the meaning of section ...
Page 94
... earnings or profits rather than a reasonable allowance as compensation for the personal services actually rendered . • " The regulations ( sec . 1.1348–3 ( a ) ( 3 ) ( i ) , Income Tax Regs . ) articulate the rule as follows : " If an ...
... earnings or profits rather than a reasonable allowance as compensation for the personal services actually rendered . • " The regulations ( sec . 1.1348–3 ( a ) ( 3 ) ( i ) , Income Tax Regs . ) articulate the rule as follows : " If an ...
Page 95
... earning a substantial portion of the gross income of petitioner's business . The earnings did not consist " principally of fees , commissions , or other compensation " ( sec . 1.1348-3 ( a ) ( 3 ) ( ii ) , Income Tax Regs . ) , but were ...
... earning a substantial portion of the gross income of petitioner's business . The earnings did not consist " principally of fees , commissions , or other compensation " ( sec . 1.1348-3 ( a ) ( 3 ) ( ii ) , Income Tax Regs . ) , but were ...
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Common terms and phrases
9th Cir accumulated profits advanced royalties affd agreement amended amount apply assets Bell County capital carryback Cayman Islands claimed Commissioner computed Congress corporation decedent decision deduction determined distribution dividend docket earnings and profits employees estate tax exempt fact Federal income tax filed foreign personal holding foreign taxes gross income guaranteed renewable held Hospital included Income Tax Regs insurance company interest Internal Revenue Internal Revenue Code Internal Revenue Service issue KFSH Knox County lease mailed management contract noncancelable notice of deficiency obligation opinion paid parties payments percent personal holding company petition petitioner petitioner's policies preliminary term method purchase purposes pursuant qualify received regulation Rept reserve respect respondent respondent's Rule Saudi Arabia shareholders shares Simarloo statute statutory supra T.C. Memo Tax Court taxable income taxpayer tion trade or business transaction U.S. dollars unearned premiums United Universal Life Church Zappo
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...