| United States. Congress. House. Committee on Agriculture - Cotton trade - 1956 - 166 pages
...applied as to defeat rather than further the purpose of Congress. Burnet v. Harmel, 287 US 103, 108. Congress intended that profits and losses arising...ordinary income or loss rather than capital gain or loss. The preferential treatment provided by § 117 applies to transactions in property which are not the... | |
| United States. Tax Court - Law reports, digests, etc - 1959 - 1372 pages
...applied as to defeat rather than further the purpose of Congress. Burnet v. Harmel, 287 US 103, 108. Congress intended that profits and losses arising...ordinary income or loss rather than capital gain or loss. The preferential treatment provided by § 117 applies to transactions in property which are not the... | |
| United States. Congress. House. Committee on Ways and Means - Income tax - 1959 - 760 pages
...applied as to defeat rather than further the purpose of Congress. Burnet v. Harmel, 287 US 103, 108. Congress intended that profits and losses arising...ordinary income or loss rather than capital gain or loss. The preferential treatment provided by [sec. 1221] applies to transactions in property which are not... | |
| United States. Congress. House Ways and Means - 1959 - 766 pages
...rather than further the purpose of Congress. Burnet v. Harmel, 287 US 103, 108. Congress intended thai profits and losses arising from the everyday operation...ordinary income or loss rather than capital gain or loss. The preferential treatment provided by [sec. 1221] applies to transactions in property which are not... | |
| United States. Internal Revenue Service - Tax administration and procedure - 1973 - 824 pages
...1221] must not be so broadly applied as to defeat rather than further the purpose of Congress. » » * Congress intended that profits and losses arising...ordinary income or loss rather than capital gain or loss. The preferential treatment provided by section 1 1 7 applied to transactions in property which are... | |
| United States. Internal Revenue Service - Internal revenue - 1978 - 630 pages
...manufacturing operations against a price increase in com. The Supreme Court held that since Congress intended profits and losses arising from the everyday operation...ordinary income or loss rather than capital gain or loss, any gains or losses the taxpayer sustained in its futures transactions were ordinary gains or losses.... | |
| United States. Internal Revenue Service - Internal revenue - 1975 - 804 pages
...asset. In Corn Products Refining Co. v. Commissioner, 350 US 46 (1955), 1955-2 CB 511, the Court said on any exemption contained in section 552 of this title to withhold from an individual any reco should be considered as ordinary income or loss rather than capital gain or loss. Thereupon, the Court... | |
| United States. Tax Court - Government publications - 1984 - 1120 pages
...hands, relying on Corn Products Refining Co. v. Commissioner, 350 US 46 (1955), and that Simarloo's gain on the sale of Dairy Farm and Hong Kong Land...Newspapers, Inc. v. United States, 157 a. Cl. 886, 303 F.2d 916, 921 (1962): if securities are purchased by a taxpayer as an integral and necessary act in the... | |
| United States. Tax Court - Government publications - 1985 - 1410 pages
...supply of corn inventory for the taxpayer's business did not qualify for capital gain treatment because, "Congress intended that profits and losses arising...loss rather than capital gain or loss." 350 US at 52. Respondent does not contend, herein, that petitioners' contract rights fall within the limitation which... | |
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