Income Tax Procedure ...Ronald Press, 1927 Editions for 1922-25 include federal capital stock tax, federal estate tax, and supplement to Excess profits tax procedure, 1921. |
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Page 6
... Government , it is likely to interpret the law narrowly as a matter of policy , on the theory that if its construction is unfavorable to the taxpayer , he will litigate it , and secure an authoritative judicial interpretation , whereas ...
... Government , it is likely to interpret the law narrowly as a matter of policy , on the theory that if its construction is unfavorable to the taxpayer , he will litigate it , and secure an authoritative judicial interpretation , whereas ...
Page 7
... government , and where as here we are satisfied . that the statute requires the construction which we have attributed to it , a Treasury regulation rises to no higher dignity than an ex- pression of opinion . " ( Douglas v . Edwards ...
... government , and where as here we are satisfied . that the statute requires the construction which we have attributed to it , a Treasury regulation rises to no higher dignity than an ex- pression of opinion . " ( Douglas v . Edwards ...
Page 9
... government.10 No object should be brought within the taxing provisions unless they clearly require the inclusion.11 On the other hand , there is some authority for the proposition that exemption provisions are to be construed strictly ...
... government.10 No object should be brought within the taxing provisions unless they clearly require the inclusion.11 On the other hand , there is some authority for the proposition that exemption provisions are to be construed strictly ...
Page 10
... Government and in favor of the taxpayer ( citing cases ) . It is not clear to us that the term " losses " in subdivision ( a ) ( 4 ) of Section 234 of the Act does not include the loss of the $ 27 , - 205.35 . Therefore , the judgment ...
... Government and in favor of the taxpayer ( citing cases ) . It is not clear to us that the term " losses " in subdivision ( a ) ( 4 ) of Section 234 of the Act does not include the loss of the $ 27 , - 205.35 . Therefore , the judgment ...
Page 20
... Government sued for additional tax contending in effect that its prior advice was incorrect . The court said : DECISION . the matter was at all times in the process of ad- justment and merely because the department made answer to a sup ...
... Government sued for additional tax contending in effect that its prior advice was incorrect . The court said : DECISION . the matter was at all times in the process of ad- justment and merely because the department made answer to a sup ...
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Common terms and phrases
additional tax allowed amended amount applicable attorney authority Board of Tax bond calendar centum certiorari Circuit Court claim for refund Co.'s Appeal collector Commissioner of Internal computed corporation counsel Court of Appeals Court of Claims credit or refund decision deduction deposition distraint District Court District of Columbia division enactment evidence excess excess-profits tax expiration February 26 fiduciary fraud Government gross income hearing held interest issue jeopardy assessment June 15 jurisdiction liability lien mailed ment motion net income notice and demand offer in compromise paid paragraph party payment person petitioner power of attorney prescribed prior procedure proceeding in court provided in section provided in subdivision regulations res adjudicata respect Revenue Act Revised Statutes rules section 274 statement statute of limitations statutory period suit Tax Appeals tax imposed taxable taxpayer testimony thereof tion Treasury waiver war-profits witness
Popular passages
Page 373 - ... the practice, pleadings, and forms and modes of proceeding existing at the time in like causes in the courts of record of the state within which such circuit or district courts are held, any rule of court to the contrary notwithstanding,
Page 456 - Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate...
Page 440 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation; but in the case of an exchange by two or more per77 L.
Page 361 - No suit or proceeding shall be maintained in any court for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected without authority, or of any sum alleged to have been excessive or in any manner wrongfully collected...
Page 454 - United allowed as a credit against the tax under section 131; and (3) taxes assessed against local benefits of a kind tending to increase the value of the property assessed...
Page 441 - ... other property or money does not distribute it in pursuance of the plan of reorganization, the gain, if any, to the corporation shall be recognized, but in an amount not in excess of the sum of such money and the fair market value of such other property so received, which is not so distributed.
Page 175 - The Commissioner of Internal Revenue, subject to regulations prescribed by the Secretary of the Treasury, is authorized to remit, refund, and pay back all taxes erroneously or illegally assessed or collected, all penalties collected without authority, and all taxes that appear to be unjustly assessed or excessive in amount, or in any manner wrongfully collected...
Page 119 - If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, penalty, additional amount, or addition to such tax, together with any costs that may accrue in addition thereto) shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.
Page 485 - An Act to provide revenue, equalize duties, and encourage the industries of the United States, and for other purposes," approved August 5, 19o9, the Act entitled "An Act to reduce tariff duties and to provide revenue for the Government, and for other purposes...
Page 456 - ... (B) from a foreign corporation unless less than 50 per centum of the gross income of such foreign corporation for the threeyear period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was derived from sources within the United States...