Reports of the United States Tax Court, Հատոր 86

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Էջ 957 - Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a): (1) CITIZENS AND DOMESTIC CORPORATIONS.— In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and (2) RESIDENT OF THE UNITED STATES OR PUERTO RICO.
Էջ 576 - 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.
Էջ 343 - The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under the method of accounting used in computing taxable income, such amount is to be properly accounted for as of a different period.
Էջ 805 - ... 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...
Էջ 488 - The Board in redetermining a deficiency in respect of any taxable year shall consider such facts with relation to the taxes for other taxable years as may be necessary correctly to redetermine the amount of such deficiency, but in so doing shall have no jurisdiction to determine whether or not the tax for any other taxable year has been overpaid or underpaid.
Էջ 805 - ... 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.
Էջ 132 - An economic interest is possessed in every case in which the taxpayer has acquired, by investment, any interest in mineral in place or standing...
Էջ 956 - ... in the year in which the taxes of the foreign country or the possession of the United States accrued, subject, however, to the conditions prescribed in subsection (c) of this section.
Էջ 1039 - We cannot too often reiterate that 'taxation is not so much concerned with the refinements of title as it is with actual command over the property taxed — the actual benefit for which the tax is paid.
Էջ 142 - 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...

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