Reports of the United States Tax Court, Opseg 76United States Tax Court, 1981 |
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5th Cir affd agreed agreement allocation allowed alumina amended amount apply assets beneficiaries Big Beef claim Club collateral estoppel Comalco compensation contends contract corporation cost decedent decedent's December 31 decision depreciation dividend Dutch elm disease employees entitled expenses facts Federal income tax fees filed gross income held hockey Income Tax Regs income tax return incurred interest Internal Revenue Code Internal Revenue Service inventory investment issue lease LIFO limited partnership loss notice of deficiency oil and gas operating opinion paid parties partners payment percent percentage depletion petition petitioner petitioner's Player prior production purchase purposes pursuant qualify reasonable received regulations Rept respect RESPONDENT Docket respondent's Seattle Totems South Devon cattle statute stipulated supra T.C. Memo tax avoidance taxable taxpayer tion trade or business transaction transfer trust United USSD vehicle Western Hockey League Whispering Hills
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Stranica 593 - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...
Stranica 826 - See section 179 and § 1.179-1 for a further description of the term "reasonable allowance." (b) Useful life. For the purpose of section 167 the estimated useful life of an asset is not necessarily the useful life inherent in the asset but is the period over which the asset may reasonably be expected to be useful to the taxpayer in his trade or business or in the production of his income.
Stranica 449 - MAINTENANCE.—If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance, the wife's gross income includes periodic payments (whether or not made at regular intervals) received after such decree in discharge of (or attributable to property transferred, in trust or otherwise, in discharge of) a legal obligation which, because of the marital or family relationship, is imposed on or incurred by the husband under the decree or under a written instrument...
Stranica 778 - ... (3) Certain tax-free transactions. If the basis of property in the hands of a transferee Is determined by reference to its basis in the hands of the transferor by reason of the application of section 332...
Stranica 1008 - No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.
Stranica 1134 - In any proceeding before the Tax Court involving a notice of deficiency based in whole or in part on the allegation that all or any part of the earnings and profits have been permitted to accumulate beyond the reasonable needs of the business...
Stranica 355 - There shall be allowed as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear (including a reasonable allowance for obsolescence) — ( 1 ) Of property used In the trade or business, or (2) Of property held for the production of Income.
Stranica 898 - ... gross income from the property excluding from such gross income an amount equal to any rents or royalties paid or incurred by the taxpayer in respect of the property. Such allowance shall not exceed 50 percent of the taxpayer's taxable income from the property (computed without allowance for depletion).
Stranica 939 - If in the case of any taxpayer, the Commissioner determines that there is a deficiency in respect of the tax imposed by this title, the Commissioner is authorized to send notice of such deficiency to the taxpayer by registered mail.
Stranica 278 - ... there shall be included in the gross income an amount which bears the same relation to the total compensation as the number of days of performance of the labor or services within the United States bears to the total number of days of performance of labor or services for which the payment is made.