The Federal ReporterWest Publishing Company, 1957 |
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Стр. 187
... interest " test and intended that test to be applicable in administration of the statute . 26 U.S. C.A. ( I.R.C.1939 ) § 112 ( b ) ( 10 ) , ( g ) ( 1 ) . 5. Internal Revenue 492 , 637 The " continuity of interest " doctrine which ...
... interest " test and intended that test to be applicable in administration of the statute . 26 U.S. C.A. ( I.R.C.1939 ) § 112 ( b ) ( 10 ) , ( g ) ( 1 ) . 5. Internal Revenue 492 , 637 The " continuity of interest " doctrine which ...
Стр. 193
... interest in the acquiring corpora- their interest in the transferor . " In the tion " by reason of , or in exchange for present case the Tax Court made what we believe was an unjustified change from " or " to " and " in this formulation ...
... interest in the acquiring corpora- their interest in the transferor . " In the tion " by reason of , or in exchange for present case the Tax Court made what we believe was an unjustified change from " or " to " and " in this formulation ...
Стр. 194
... interests . " Just as there is no continuity of interest if the stock of the acquiring corporation goes to a new party who supplies addi- tional capital , so too there is no con- tinuity of interest if the new stock goes to " old " or ...
... interests . " Just as there is no continuity of interest if the stock of the acquiring corporation goes to a new party who supplies addi- tional capital , so too there is no con- tinuity of interest if the new stock goes to " old " or ...
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action affirmed agree agreement alleged amended amount appellant appellee application authority basis Board cause charge Circuit Judge Cite as 236 City claim Commission Company condition considered contract corporation Court of Appeals damages decision defendant denied determination direct District Court effect employees entered entitled established evidence fact failed Federal filed finding further hearing held hold income Indians indictment insured interest Internal Revenue Internal Revenue Code involved issue judgment jurisdiction jury L.Ed Labor liability limited matter ment motion natural negligence notes operation opinion parties patent payments person petitioner plaintiff present prior proceeding question reason received record refused Relations respect result rule S.Ct statement statute suit testimony tion trial trust union United violation witness York