WebMar 7, 1988 · No. 86-751. Argued December 9, 1987 Decided March 7, 1988. Under § 1221 of the Internal Revenue Code, the term "capital asset" means "property held by the taxpayer (whether or not connected with his trade or business), but does not include" five specified classes of property. Between 1968 and 1974, petitioner, a diversified holding company ... WebCommissioner - 313 U.S. 28, 61 S. Ct. 757 (1941) Rule: Where the disputed amount is essentially a substitute for rental payments, which § 22(a) of the Revenue Act of 1932 …
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WebCommissioner, 345 U.S. 544, 73 S.Ct. 848, 97 L.Ed. 1232; an unexpired lease, Hort v. Commissioner, 313 U.S. 28, 61 S.Ct. 757, 85 L.Ed. 1168; and oil payment rights, Commissioner v. P. G. Lake, Inc., 356 U.S. 260, 78 S.Ct. 691, 2 L.Ed.2d 743. WebSee United States v. Gilmore, 372 U.S. 39, 49 (1963); and Hort v. Commissioner, 313 U.S. 28 (1941). 5 See Raytheon Production Corp. v. Commissioner, 144 F.2d 110, 113 (1st Cir. 1944); and LTR 200108029. or third party content.)RUPRUHTax Notes® Federal FRQWHQW SOHDVHYLVLWZZZ WD[QRWHV FRP
WebCommissioner Hort v. Commissioner 313 U.S. 28 (1941) Hort owned an office building that was being leased by Irving Trust. They had a fifteen-year lease, but decided to close that … WebHort v. Commissioner, 313 U.S. 28, 61 S. Ct. 757, 85 L. Ed. 1168, 41-1 U.S. Tax Cas. (CCH) P9354, 25 A.F.T.R. (P-H) 1207, 1941-1 C.B. 319, 1941 P.H. P62,041 (U.S. Mar. 31, 1941) Powered by Law Students: Don’t know your Bloomberg Law login? Register here Brief Fact …
WebDec 19, 2007 · Commissioner, Commissioner v. P.G. Lake, Inc., Commissioner v. Gillette Motor Transport, Inc., and United States v. Midland-Ross Corp. The taxpayer in Hort, 313 U.S. 28, 29, 61 S.Ct. 757, 757, 85 L.Ed. 1168 (1941), a building owner, received a lump sum in exchange for cancelling a lease on the property. The sum was taxable as ordinary income ... WebSee also Hort v. Commissioner, 313 U.S. 28, 31, 61 S.Ct. 757, 85 L.Ed. 1168 (1941). Taxpayer's argument that he received the stock and cash as a "bequest" under New York law and the decisions of the surrogates is thus beside the point. New York law does, of course, control as to the extent of the taxpayer's legal rights to the property in ...
WebCommissioner, 345 U. S. 544; an unexpired lease, Hort v. Commissioner, 313 U. S. 28; and oil payment rights, Commissioner v. P. G. Lake, Inc., 356 U. S. 260.
WebU.S. Reports: Hort v. Commissioner, 313 U.S. 28 (1941). Murphy, Frank (Judge) Supreme Court of the United States (Author) 1940 - Taxation - Real Estate - Law - Law Library - … teamwork movies on netflixWebThat such a claim cannot be the basis for a Section 23 (f) loss deduction is clearly established by Hort v. Commissioner, 313 U.S. 28, 61 S. Ct. 757, 85 L. Ed. 1168 (1941). In that case the Supreme Court set forth the rule that a loss of potential income is not a deductible loss within the meaning of the capital loss provisions. teamwork natureWebHort v. Commissioner 313 U.S. 28 (1941) Study Aids Case Briefs Overview Casebooks Case Briefs H From our private database of 36,700+ case briefs... Hort v. Commissioner United … teamwork navyWebHort v. Commissioner, supra, 313 U.S., at 31, 61 S.Ct., at 758. The $6 earned on a one-year note for $106 issued for $100 is precisely like the $6 earned on a one-year loan of $100 at 6% stated interest. The application of general principles would indicate, therefore, ... teamwork navy sealsWebArkansas Best Corp. v. Commissioner, 485 U.S. 212 (1988) Arkansas Best Corp. v. Commissioner of Internal Revenue. No. 86-751. Argued December 9, 1987. Decided … teamwork muralWebThe Commissioner included the entire $140,000 in gross income, disallowed the asserted loss, made certain other adjustments not material here, and assessed a deficiency. The … spain segunda division forebet predictionWebIn Hort v. Commissioner, 313 U.S. 28, 61 S.Ct. 757, 85 L.Ed. 1168, wherein the landlord released his tenant from a 15-year lease upon payment of a lump-sum in cash, there … spain security guard salary