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accounting acquired activity additional agree agreement allowed amount apply argues assets basis benefit capital cash claim Coal Commissioner contract contribution corporation cost Court December deductions deficiency determined distribution economic effect entered executed expenses fact Federal fees filed follows Form franchise gross held holding income tax individual interest Internal Revenue Internal Revenue Code investment issue lease liability limited loss meaning method mineral mining nonrecourse notice obligation operating opinion organization paid parties partnership payment percent period petitioner petitioner's position principal prior production profit promissory note purchase pursuant reasonable received record references regulations reserves respect respondent respondent's result Rule Service share straddle substantial supra Tax Regs tax return taxable taxpayer term terminals tion trade transaction transfer trust United
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 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.