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abnormal income accounting allowed amended amount applied Article assets bankruptcy banks base period basis capital gain capital stock CCH Dec cent cited at footnote claim Code Sec Code Section Cohan collector Commissioner Company contract corporation cost December 31 decision deduction depreciation determining dividends earnings effect employees estate tax excess profits tax exemption expenses fact federal tax filed gross income held Helvering income tax interest Internal Revenue Jerry Rossman Learned Hand lease LIFO loss ment method net income operations ordinary income paid payer payment due prior problem provides purchase reason received refund Regs Regulations relief reorganization reports and payment result Revenue Act rule sales tax Section 722 statute Supreme Court Tax Court tax due tax laws tax lien tax purposes tax reports tax return taxable taxation taxpayer tion Treasury trust United USTC valuation York