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" To constitute receipt in such a case the income must be credited or set apart to the taxpayer without any substantial limitation or restriction as to the time or manner of payment or condition upon which payment is to be made, and must be made available... "
Prentice-Hall Tax Service for 1919 (Classic Reprint) - Page 273
by Prentice-Hall Inc, Prentice-Hall, inc - 1919 - 424 pages
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Cases Decided in the Court of Claims of the United States, Volume 69

United States. Court of Claims - Law reports, digests, etc - 1930 - 854 pages
...received such amount when the account may be drawn upon by him at any time and there was no substantial limitation or restriction as to the time or manner...payment or condition upon which payment is to be made." That was exactly the situation in this case. Such sums, from the dates when they were credited on plaintiff's...
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Cases Decided in the United States Court of Claims ... with ..., Volume 136

United States. Court of Claims, Audrey Bernhardt - Law reports, digests, etc - 1957 - 904 pages
...so that it may be drawn at any time, and ite receipt brought within his own control and disposition. A book entry, if made, should indicate an absolute transfer from one account to another. It is the conclusion of the court that the plaintiff received no part of his fee for services performed...
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Canada; Economic Position and Plans for Development

Guaranty Trust Company of New York - Canada - 1919 - 664 pages
...constitute receipt it is necessary in such cases for the income to be credited without any substantial limitation or restriction as to the time or manner...payment or condition upon which payment is to be made, and where book entries are made they should indicate an absolute transfer from one account to another....
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Taxation of Corporations and Personal Income in New York

Henry Montefiore Powell - Corporations - 1919 - 708 pages
...constitute receipt in such a case the income- nraet be credited ft> ttĀ» tasparyer without any substantial limitation or restriction as to the time or manner of payment or condition upon which paynwnt is to be made:. A book entry-, if raacfo, should indicate an absahrte transfear from one account...
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Comptroller's Regulations Relating to the Income Tax Issued Pursuant to ...

Income tax - 1920 - 188 pages
...constitute receipt in such a case the income must be credited to the taxpayer without any substantial limitation or restriction as to the time or manner...unqualifiedly subject to the demand of the taxpayer. For example, where a corporation contingently credits its employees with bonus stock, but the stock...
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Cumulative Bulletin ... Income Tax Rulings, Issues 4-5

United States. Bureau of Internal Revenue - Income tax - 1921 - 772 pages
...constitute receipt in such a case the income must be credited to the taxpayer without any substantial limitation or restriction as to the time or manner of payment or condition upon which payment is to bi> made. In the instant case the dividend was not in money hut in stock of four corporation;;, with...
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Pamphlets, Volumes 45-46

Irving National Bank, New York - 1921 - 140 pages
...actually reduced to possession. To constitute receipt the income must be credited without any substantial limitation or restriction as to the time or manner of payment, or condition upon which payment is made. A book entry, if made, should indicate an absolute transfer from one account to another. If the...
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Treasury Decisions Under Internal Revenue Laws of the United States, Volume 27

United States. Internal Revenue Service - Taxation - 1926 - 620 pages
...constitute receipt in such a case, the income must be credited to the taxpayer without any substantial limitation or restriction as to the time or manner...absolute transfer from one account to another. If income u not credited, but is set apart, such income must be unqualifiedly subject to the demand of...
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The Federal Reporter

Law reports, digests, etc - 1928 - 1138 pages
...taxpayer, is taxable, has declared it may only be taxed when credited to him without any substantial limitation or restriction as to the time or manner...payment or condition upon which payment is to be made. See Regulations 45, articles 11 16, inclusive. The Board of Tax Appeals, in its decision in the present...
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Treasury Decisions Under Internal Revenue Laws of the United States, Volume 30

United States. Internal Revenue Service - Taxation - 1929 - 478 pages
...taxpayer, is taxable, has declared it may only be taxed when credited to him without any substantial limitation or restriction as to the time or manner...payment or condition upon which payment is to be made. (See Regulations 45, arts. 44-46, inclusive.) The Board of Tax Appeals, in its decision in the present...
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