Reports of the Tax Court of the United States, Volume 81U.S. Government Printing Office, 1984 - Taxation |
From inside the book
Results 1-5 of 43
Page 448
... Simarloo's shares . During its fiscal year ended June 30 , 1973 , Simarloo sold X corporation shares at a profit of $ A1,200,052 . Translated to U.S. dollars , Simarloo's gain was $ 1,595,231 , $ 250,016 of which was foreign currency ...
... Simarloo's shares . During its fiscal year ended June 30 , 1973 , Simarloo sold X corporation shares at a profit of $ A1,200,052 . Translated to U.S. dollars , Simarloo's gain was $ 1,595,231 , $ 250,016 of which was foreign currency ...
Page 449
... Simarloo's gross income for its fiscal year ended June 30 , 1973 , is therefore gain from the sale of securities . Held , further , Simarloo had a substantial investment motive for holding its X corporation shares during its fiscal year ...
... Simarloo's gross income for its fiscal year ended June 30 , 1973 , is therefore gain from the sale of securities . Held , further , Simarloo had a substantial investment motive for holding its X corporation shares during its fiscal year ...
Page 450
... Simarloo Pty . , Ltd. ( hereinafter Simarloo ) , an Australian corporation organized under the laws of the State of South Australia . After concessions by the parties , the following issues remain for our decision : ( 1 ) Was Simarloo a ...
... Simarloo Pty . , Ltd. ( hereinafter Simarloo ) , an Australian corporation organized under the laws of the State of South Australia . After concessions by the parties , the following issues remain for our decision : ( 1 ) Was Simarloo a ...
Page 451
... Simarloo shares pursuant to section 551 ( e ) for purposes of calculating its dividends paid deduction under section 562 ; ( 6 ) Is respondent barred by the statute of limitations from assessing liabilities against the transferees of ...
... Simarloo shares pursuant to section 551 ( e ) for purposes of calculating its dividends paid deduction under section 562 ; ( 6 ) Is respondent barred by the statute of limitations from assessing liabilities against the transferees of ...
Page 452
... Simarloo . Dairy Farm was a large , publicly traded Hong Kong corporation that owned and operated retail stores that offered an outlet for Simarloo's produce . Simarloo's motive for seeking to induce Dairy Farm to become a shareholder ...
... Simarloo . Dairy Farm was a large , publicly traded Hong Kong corporation that owned and operated retail stores that offered an outlet for Simarloo's produce . Simarloo's motive for seeking to induce Dairy Farm to become a shareholder ...
Other editions - View all
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 deduction determined distribution dividend docket earnings and profits employees estate tax expenses 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 loan 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 742 - ... 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 468 - An individual shall be considered as owning the stock owned, directly or indirectly, by or for his family or by or for his partner.
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 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 951 - ... no assessment of a deficiency in respect of any tax imposed by subtitle A or B and no levy or proceeding in court for its collection shall be made, begun, or prosecuted until such notice has been mailed to the taxpayer, nor until the expiration of such...
Page 334 - For purposes of this subtitle, the term "life insurance company" means an insurance company which is engaged in the business of issuing life insurance and annuity contracts (either separately or combined with health and accident insurance), or noncancellable contracts of health and accident insurance...
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 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...
Page 479 - Congress intended that profits and losses arising from the everyday operation of a business be considered as ordinary income or loss rather than capital gain or loss.