Reports of the United States Tax Court, 69권U.S. Government Printing Office, 1978 |
도서 본문에서
88개의 결과 중 1 - 5개
3 페이지
... constituted " payment " thereof , and that we should look to Maryland law to determine whether the provisions of section 545 ( c ) ( 1 ) are satisfied . Respondent asserts that the mere distribution of assets in liquidation , coupled ...
... constituted " payment " thereof , and that we should look to Maryland law to determine whether the provisions of section 545 ( c ) ( 1 ) are satisfied . Respondent asserts that the mere distribution of assets in liquidation , coupled ...
4 페이지
... cash basis taxpayer and therefore did not reach the question whether assumption of such liabilities constituted " payment . " ESTATE OF ANNA LORA GILCHRIST , DECEASED , LAYLAND MYATT 4 ( 1 ) 69 UNITED STATES TAX COURT REPORTS.
... cash basis taxpayer and therefore did not reach the question whether assumption of such liabilities constituted " payment . " ESTATE OF ANNA LORA GILCHRIST , DECEASED , LAYLAND MYATT 4 ( 1 ) 69 UNITED STATES TAX COURT REPORTS.
16 페이지
... constituted a lapse of the power in each year that it was not exercised . Such lapse constituted a release of the power under sec . 2041 ( b ) ( 2 ) in such a way that , if it were a transfer of property owned by the decedent , the ...
... constituted a lapse of the power in each year that it was not exercised . Such lapse constituted a release of the power under sec . 2041 ( b ) ( 2 ) in such a way that , if it were a transfer of property owned by the decedent , the ...
37 페이지
... constituting a 0.75 - percent interest in the company . The trusts were irrevocable and were to terminate upon the beneficiaries ' reaching 21 years of age . The trustee of each trust was authorized to apply income and principal for the ...
... constituting a 0.75 - percent interest in the company . The trusts were irrevocable and were to terminate upon the beneficiaries ' reaching 21 years of age . The trustee of each trust was authorized to apply income and principal for the ...
38 페이지
... constituting a 0.75 - percent interest in the company . The trust terms were identical to those of the trusts created by Bruno , with the exception that Bruno was named trustee of each trust . Bruno and Bertha died prior to the ...
... constituting a 0.75 - percent interest in the company . The trust terms were identical to those of the trusts created by Bruno , with the exception that Bruno was named trustee of each trust . Bruno and Bertha died prior to the ...
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5th Cir addition to tax adjusted basis affd agreement allocation amended amount application assets Bank bankruptcy beneficiary benefit capital cash CBCC charitable claimed COMMISSIONER OF INTERNAL community property contract contributions Corp corporation death debt decedent decedent's December 31 decision deduction distributions employees ended September 30 entitled estate tax exempt expenses facts fair market value Federal income tax Feroleto filed funds gift tax gross estate gross income held Holgersons included Income Tax Regs income tax return inheritance tax interest Internal Revenue Code Internal Revenue Service issue liability loan notice of deficiency operating loss opinion oyster paid parties partnership payment percent petition petitioner petitioner's prior purchase purposes pursuant qualify received respect Respondent determined RESPONDENT Docket respondent's securities September 30 shareholders shares statutory stipulated supra taxable income taxable year ended taxpayer transaction transfer United unpaid losses
인기 인용구
xiv 페이지 - O divine Master, grant that I may not so much seek to be consoled as to console; to be understood as to understand; to be loved as to love; for it is in giving that we receive, it is in pardoning that we are pardoned, and it is in dying that we are born to eternal life.
491 페이지 - ... organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or...
306 페이지 - All laws should receive a sensible construction. General terms should be so limited in their application as not to lead to injustice, oppression, or an absurd consequence. It will always, therefore, be presumed that the legislature intended exceptions to its language, which would avoid results of this character. The reason of the law in such cases should prevail over its letter.
663 페이지 - In the case of a series of transactions, the date of the last such transaction) ; and (B) stock of the distributing corporation possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
307 페이지 - It is a familiar rule that a thing may be within the letter of the statute and yet not within the statute, because not within its spirit, nor within the intention of its makers.
252 페이지 - Joint names and payable to either or the survivor, except such part thereof as may be shown to have originally belonged to such other person and never to have been received or acquired by the latter from the decedent for less than an adequate and full consideration in money or money's worth...
42 페이지 - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
23 페이지 - Upon the adjudication of bankruptcy of any taxpayer in any bankruptcy proceeding or the appointment of a receiver for any taxpayer in any receivership proceeding before any court of the United States or of any State or Territory or of the District of Columbia, any deficiency (together with all interest, additional amounts, or additions to the tax provided for by law...
515 페이지 - Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subject to substantial limitations or restrictions.
210 페이지 - In any case of two or more organizations, trades, or businesses (whether or not Incorporated, whether or not organized In the United States, and whether or not affiliated) owned or controlled directly or Indirectly by the same Interests...