Cases Decided in the United States Court of Claims ... with Report of Decisions of the Supreme Court in Court of Claims Cases, Volume 151The Court, 1963 |
From inside the book
Results 1-5 of 87
Page 56
... income of $ 391,000 for each of the following three years " in order to provide for amortization and a fair return on capital invested , in addition to the recovery of ordinary and necessary operating costs . " Plaintiff stated that ...
... income of $ 391,000 for each of the following three years " in order to provide for amortization and a fair return on capital invested , in addition to the recovery of ordinary and necessary operating costs . " Plaintiff stated that ...
Page 128
... income ; recognition of gain or loss - tax - free reorganization.— In a suit by representatives of two deceased principal stock- holders of the Phoenix Hosiery Company to recover income taxes alleged to have been erroneously assessed ...
... income ; recognition of gain or loss - tax - free reorganization.— In a suit by representatives of two deceased principal stock- holders of the Phoenix Hosiery Company to recover income taxes alleged to have been erroneously assessed ...
Page 129
... income ; recognition of gain or loss ; reorganization - con- tinuity of interest rule . - The continuity of interest rule was devised as a means for denying tax benefits to transactions which are outside the intended scope of the tax ...
... income ; recognition of gain or loss ; reorganization - con- tinuity of interest rule . - The continuity of interest rule was devised as a means for denying tax benefits to transactions which are outside the intended scope of the tax ...
Page 130
... income ; deductions ; losses ; transactions entered into for profit . - A shareholder of a corporation who sells his securities to key employees at a price below market value usually does so with the expectation of increased profits by ...
... income ; deductions ; losses ; transactions entered into for profit . - A shareholder of a corporation who sells his securities to key employees at a price below market value usually does so with the expectation of increased profits by ...
Page 131
... income tax purposes . Although § 112 ( g ) states that recapitalization is one form of reorganization , the statute does not tell us what recapitali- zation means . Nor do the Regulations attempt a clear - cut definition . The Supreme ...
... income tax purposes . Although § 112 ( g ) states that recapitalization is one form of reorganization , the statute does not tell us what recapitali- zation means . Nor do the Regulations attempt a clear - cut definition . The Supreme ...
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Common terms and phrases
A. P. Green action active duty agency Alaska Road Commission alleged allowed amount Anchorage assigned charges Civil Service Commission civilian claim Coast Guard contracting officer Contractor corporation cost Court 151 Ct court-martial Crow Nation Crow Tribe damages December decision deduction defendant defendant's denied desks determined dismissed District Engineer dividend tax employees entitled to recover evidence excess profits tax Fact 151 Ct filed Findings of Fact George Cochran Government grade hearing Heilman Herman Gardner income Indian Internal Revenue Internal Revenue Code Judge judgment July June June 18 Kalinowski letter Marine ment Narum Navy night differential October operation overtime paid parties payment percent period personnel petition plaintiff plant preferred stock pursuant reason received refastening regulations request retired pay scheduled September Shadrick sketches specifications Stat statute summary judgment termination tion treaty trial Tribe tungsten U.S. Marine Corps United Veterans Wisconsin witnesses
Popular passages
Page 305 - State, and whenever on the line thereof, the United States have full title, not reserved, sold, granted or otherwise appropriated, and free from preemption, or other claims or rights, at the time the line of said road is definitely fixed...
Page 360 - Title III of the Army and Air Force Vitalization and Retirement Equalization Act of 1948...
Page 151 - ... giving and granting unto my said attorney full power and authority to do and perform all and every act and thing whatsoever requisite and necessary to be done in and about the premises, as fully to all intents and purposes as I might or could do if personally present...
Page 93 - The Contractor shall keep on the work a copy of the drawings and specifications and shall at all times give the Contracting Officer access thereto. Anything mentioned in the specifications and not shown on the drawings, or shown on the drawings and not mentioned in the specifications, shall be of like effect as if shown or mentioned in both.
Page 545 - In the event the Government terminates this contract in whole or in part as provided in paragraph (a) of this clause, the Government may procure, upon such terms and in such manner as the Contracting Officer may deem appropriate, supplies or services similar to those so terminated...
Page 139 - All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, • *••••••••••••• "(2) Non-trade or non-business expenses. "In the case of an Individual, all the ordinary and necessary expenses paid or incurred during the taxable year for the production or collection of income, or for the management, conservation, or maintenance of property held for the production of income.
Page 136 - Certainly, we think that to be within the exemption the seller must acquire an interest in the affairs of the purchasing company more definite than that incident to ownership of its short-term purchase-money notes.
Page 94 - DISPUTES (a) Except as otherwise provided in this contract, any dispute concerning a question of fact arising under this contract which is not disposed of by agreement shall be decided by the Contracting Officer, who shall reduce his decision to writing and mail or otherwise furnish a copy thereof to the Contractor.
Page 95 - In connection with any appeal proceeding under this clause, the Contractor shall be afforded an opportunity to be heard and to offer evidence in support, of its appeal. Pending final decision of a dispute hereuMer, the Contractor shall proceed diligently with the performance of the contract and in accordance with the Contracting Officer's decision. (b) This "Disputes...
Page xiii - States without license of the owner thereof or lawful right to use or manufacture the same, the owner's remedy shall be by action against the United States in the Court of Claims for the recovery of his reasonable and entire compensation for such use and manufacture.