U.S. Tax Cases, Volume 44, Parts 1-2Commerce Clearing House., 1951 - Income tax 1935-42 decisions originally reported currently in the Standard federal tax service, and 1941-42 also in the Federal estate and gift tax service, and 19 - in the Federal excise tax reports. |
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Page 268
... stockholders of the lessor . The decision was placed on the ground that because of the direct con- tractual rights which ran to the stockholders 1 the lessor had lost control over the rentals and consequently was not subject to a tax ...
... stockholders of the lessor . The decision was placed on the ground that because of the direct con- tractual rights which ran to the stockholders 1 the lessor had lost control over the rentals and consequently was not subject to a tax ...
Page 359
... stockholders or whether it is enough that the persons having control of the new company were former stockholders although they received the stock in the present corporation in their capacity as creditors of the old company . The Tax ...
... stockholders or whether it is enough that the persons having control of the new company were former stockholders although they received the stock in the present corporation in their capacity as creditors of the old company . The Tax ...
Page 360
... stockholders as stockholders . Had the congressional inten- tion been otherwise the clause would not have used the word " stockholders " . This view finds support in the dictum of the Supreme Court in Helvering v . Alabama Asphaltic ...
... stockholders as stockholders . Had the congressional inten- tion been otherwise the clause would not have used the word " stockholders " . This view finds support in the dictum of the Supreme Court in Helvering v . Alabama Asphaltic ...
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affirmed agreement allowed amended amount appellee applicable assessed assets Attorney Bank basis beneficiaries Board of Tax capital stock CCH Dec certiorari Circuit Court Circuit Judges claim for refund Collector of Internal Commissioner of Internal Company contract corporation Court holds Court of Appeals death decedent decedent's decision deduction defendant deficiency depreciation determined distribution District Court dividends entitled fact filed gift tax gross income held Helvering income tax interest Internal Revenue Internal Revenue Code issue judgment lease liability lien loss memorandum decision ment Nebel net income opinion paid par value payment petition for review petitioner plaintiff preferred stock profits purchase question received Regulations res judicata respondent Revenue Act sald Section securities settlor Sewall Key shares Stat statute stockholders supra Tax Appeals Tax Court tax return taxable taxpayer term tion transaction transfer trust trust instrument U. S. Attorney United States Circuit USTC