Reports of the United States Tax Court, Том 82United States Tax Court, 1984 |
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Стр. 16
... fact , the Supreme Court has questioned whether is is even proper to characterize the relation - back of the first regulation to the effective date of the interpreted Code section as being a retroactive application of the regulation ...
... fact , the Supreme Court has questioned whether is is even proper to characterize the relation - back of the first regulation to the effective date of the interpreted Code section as being a retroactive application of the regulation ...
Стр. 31
... facts , it is concluded that the administrative record before us presents a fact situation at the family mission level similar to that found in Basic Bible Church v . Commissioner , supra , and McGahen v . Commissioner , supra . Whether ...
... facts , it is concluded that the administrative record before us presents a fact situation at the family mission level similar to that found in Basic Bible Church v . Commissioner , supra , and McGahen v . Commissioner , supra . Whether ...
Стр. 42
... fact that allowance of a dollar amount as a marital deduction opens the door to part of the marital estate escaping taxation , thus giving the common law States an advantage over community property States equalization of which was the ...
... fact that allowance of a dollar amount as a marital deduction opens the door to part of the marital estate escaping taxation , thus giving the common law States an advantage over community property States equalization of which was the ...
Стр. 59
... fact used to pay three initial premiums of $ 713 each on policies on decedent's life of which the trustee was the owner and beneficiary . The District Court had held that , for purposes of section 2035 , the decedent transferred the ...
... fact used to pay three initial premiums of $ 713 each on policies on decedent's life of which the trustee was the owner and beneficiary . The District Court had held that , for purposes of section 2035 , the decedent transferred the ...
Стр. 60
... fact decedent may12 not have formally acquired and then trans- ferred the ownership rights in the policy is immaterial . Detroit Bank & Trust Co. v . United States , 467 F.2d at 967-968 . The application for the policy specifically ...
... fact decedent may12 not have formally acquired and then trans- ferred the ownership rights in the policy is immaterial . Detroit Bank & Trust Co. v . United States , 467 F.2d at 967-968 . The application for the policy specifically ...
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9th Cir activities affd affg agree agreement amended Amerco amount annuity apply assets benefit capital gains Centronics Circuit Cirelli claimed Colbert County community property Congress contract contributions corporation cost decedent decedent's December 31 decision employee entitled estate tax exempt expenses fact Federal income tax filed fleet owner gift tax gross income Harwood held hereinafter home office included Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service investment issue lease lessees liability loss marital deduction mineral motion muriate notice of deficiency operation opinion paid parties partner partnership payments percent petition petitioner petitioner's portion prior purchase purposes pursuant qualified received regulations rent rental reported respect Respondent determined RESPONDENT Docket respondent's spouse statute statutory stipulated substantial supra T.C. Memo taxpayer timber tion trade or business trailers transaction transfer trust U-Haul United
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Стр. 28 - ... 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...
Стр. 50 - [a] word is not a crystal, transparent and unchanged, it is the skin of a living thought and may vary greatly in color and content according to the circumstances and the time in which it is used.
Стр. 228 - 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, IB Imposed on or Incurred by the husband under the decree or under a written instrument incident to such...
Стр. 313 - Court itself recognized that the purpose of the exclusionary rule "is to deter — to compel respect for the constitutional guaranty in the only effectively available way — by removing the incentive to disregard it.
Стр. 849 - Corporations, and any community chest, fund, or foundation, 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...
Стр. 590 - The amount of all such items shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under methods of accounting permitted under subdivision (b) of section 212, any such amounts are to be properly accounted for as of a different period...
Стр. 994 - The question is phrased in terms of 'prohibition' rather than 'authorization' because a survey of our cases shows that judicial review of a final agency action by an aggrieved person will not be cut off unless there is persuasive reason to believe that such was the purpose of Congress.
Стр. 157 - ... the amount actually distributed or made available to any distributee shall be taxable to him in the year in which so distributed or made available to the extent that it exceeds the amounts paid in by him.
Стр. 159 - In the case of an employees' trust described in section 401(a), which is exempt from tax under section 501(a), if the total distributions payable with respect to any employee are paid to the distributee within 1 taxable year of the distributee on account of the employee's death or other separation from the service...
Стр. 212 - Except as otherwise provided in this subtitle, gross income means all income from whatever source derived, including (but not limited to) the following items: (1) Compensation for services, including fees, commissions, and similar items; (2) Gross income derived from business; (3) Gains derived from dealings in property...