...consideration. The alternative allocation is therefore not before us. "See 26 CFR § 1.482-1 (a) (6) (1971). ' B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders, 15-21 (3ded. 1971), payer dealing at arm's length with another uncontrolled taxpayer.10 The question...

...Bradbury v. Commissioner, 298 F. 2d 111, 116-117 (CA 1st Cir. 1962). •See Treas. Reg. 1.302-2 (b). 7 See B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders 292 n. 32 (2d ed. 1966). 301 Opinion of the Court continued to be made specifically applicable to the...

...Bradbury v. Commissioner, 298 F. 2d 111, 116-117 (CA 1st Cir. 1962). 6 See Treaa. Reg. 1.302-2 (b). 7 See B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders 292 n. 32 (2d ed. 1966). 301 Opinion of the Court continued to be made specifically applicable to the...

...was made. The Internal Revenue Code does not specifically define the phrase "earnings and profits." See B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders, par. 7.03 (5th ed. 1987). Earnings and profits in the tax sense, although the term does not correspond...

...substantially disproportionate as to one shareholder but not as to the other concerned shareholders. See B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders, par. 9.22, p. 9-16 (3d ed. 1971). As the facts clearly indicate, the resolution of this issue is not...

...Commissioner, 55 TC 204, 232 (1970); Texas-Canadian Oil Corp., Ltd. v. Commissioner, 44 BTA 913 (1941); B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders, par. 17.40, at 17-73 (4th ed. 1979). The Tax Reform Act of 1976 amended section 367 by establishing...

...not apply when hostility exists among the members of a family. Haft Trust v. Commis29 See generally B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders, par. 9.24, at 9-29 to 9-34 (4th ed. 1979). sioner, 61 TC at 403. We rejected that argument, analyzing...

...Rep. No. 1337, 83d. Cong., 2d Sess., A128 (1954) ; S. Rep. No. 1622, 83d Cong., 2d Sess., 272 (1954) ; B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders 13.14, pp. 3-51 and n. 81 (3d ed. 1971); 3A J. Mertens, Law of Federal Income Taxation §21.134 (1968...

...reconsidered. No. 73-134. "COLE v. TENNESSEE. Ct. Grim. App. Tenn. Motion to dispense with printing petition 7 See B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders 9-2 (3d ed. 1971). 8 It has been suggested thitt since Davis was decided March 23, 1970, Congress has...

...rise to taxable income to the recipient. For a description of its role in corporate reorganizations, see B. Bittker & J. Eustice, FEDERAL INCOME TAXATION OF CORPORATIONS AND SHAREHOLDERS, § 12.34 (1966). 13. In this regard, see the discussion regarding seller's expenses in Sections 4.3.3....