Reports of the Tax Court of the United States, Band 49U.S. Government Printing Office, 1968 |
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agreement amount apply assets attorney basis capital gains cash claim common stock community property contract corporation cost death decedent decedent's December December 31 decision decree deduction distribution district director Electric employee entitled estate tax exchange fair market value Federal income tax fees filed gift gift tax gross estate gross income Harriston Lumber held hereinafter income tax return incurred installment interest Internal Revenue Code issue January June June 30 lease liability liquidation litigation ment obligation operating loss opinion option ordinary and necessary ordinary income paid parties partnership payable payment percent period Perry peti petition petitioner petitioner's Pinsetter pinspotter Porter preferred stock prior purchase purpose receipts received record respect Respondent determined RESPONDENT Docket respondent's restricted stock shareholders shares statute stipulated stockholders supra tax return taxpayer tion tioner transaction transfer trust wife WJIV
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Seite 342 - 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 259 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment...
Seite 143 - ... 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 533 - Rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or Is not taking title or In which he has no equity.
Seite 469 - ... 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.
Seite 114 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
Seite 665 - As used in this subsection, the term "security" means any bond, debenture, note, or certificate or other evidence of indebtedness, issued by any corporation (including one issued by a government or political subdivision thereof), with interest coupons or in registered form...
Seite 178 - A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
Seite 593 - 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...
Seite 519 - For the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including amounts paid for accident or health insurance) , or (B) For transportation primarily for and essential to medical care referred to in subparagraph (A).