Reports of the Tax Court of the United States, Band 1U.S. Government Printing Office, 1943 |
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accrued agreement amended amount assets bank basis beneficiaries bonds calendar capital stock cash certificates claimed COMMISSIONER OF INTERNAL common stock community property computing contends contract Corning Glass corporation corpus Court creditors death debentures debt decedent decedent's December December 31 decision deduction deficiency determined distribution Docket entitled excess profits tax executors expenses fair market value filed FINDINGS OF FACT follows fund gain gift tax grantor gross income held Helvering holders included income tax income tax return indebtedness interest INTERNAL REVENUE issue January January 31 lease liability mortgage net income obligation opinion par value parties payable payment percent period peti petitioner petitioner's preferred stock premiums principal prior proceeding purchase question received reported reserve respect respondent Revenue Act royalties section 112 securities shareholders shares statute stipulated stockholders supra taxpayer thereof tion tioner transaction transfer treasury stock trust trust instrument wife
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Seite 659 - Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived...
Seite 521 - ... 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...
Seite 70 - ... if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Seite 677 - If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend...
Seite 549 - ... the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Seite 549 - Any transfer of a material part of his property in the nature of a final disposition or distribution thereof, made by the decedent within two years prior to his death without such a consideration, shall, unless shown to the contrary, be deemed to have been made in contemplation of death within the meaning of this title...
Seite 631 - ... (b) Sales of Realty and Casual Sales of Personalty. — In the case (1) of a casual sale or other casual disposition of personal property (other than property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year), for a price exceeding $1,000...
Seite 95 - ... one of a series of distributions) in complete cancellation or redemption...
Seite 714 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Seite 368 - In the case of property held in trust, the allowable deduction shall be apportioned between the income beneficiaries and the trustee in accordance with the pertinent provisions of the instrument creating the trust, or, in the absence of such provisions, on the basis of the trust income allocable to each.