Revenue and Spending Proposals for Fiscal Year 1990: Hearing Before the Committee on Finance, United States Senate, One Hundred First Congress, First Session, Part 2

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U.S. Government Printing Office, 1989

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Page 104 - ... definitely be allocated to some item or class of gross income. The remainder, if any, shall be included in full as net income from sources within the United States.
Page 76 - The majority of these cases have involved real estate sales, and the sale of equipment held for rental (or for rental and then sale). In both instances, the litigation generally revolves around the question of the "primary" purpose for which the property was held.
Page 79 - US 212 (1988), the Supreme Court rejected a taxpayer claim for ordinary loss treatment on the sale of stock of a bank that had been 65 percent owned by the taxpayer's holding company. The Supreme Court stated that Corn Products is properly interpreted as standing for the narrow proposition that hedging transactions that are an integral part of a business' inventory-purchase system fall within the inventory exclusion of the Code.
Page 113 - In the case of an individual who owns an interest in an unincorporated trade or business, who is a beneficiary of a trust or estate, who is a partner in a partnership, or who is a shareholder in a...
Page 76 - Inventory and property held primarily for sale to customers in the ordinary course of the taxpayer's trade or business are excluded from the definition of a capital asset. The object of this exclusion is to preclude capital gains treatment for receipts obtained in the routine conduct of the taxpayer's enterprises. A host of cases have been litigated over whether gain received by the taxpayer was attributable to the sale of property held primarily for sale to customers in the ordinary course of the...
Page 111 - ... research floors plus (b) an amount reflecting any decrease in nonresearch giving to universities by the corporation as compared to such giving during a fixed-base period, as adjusted for inflation. This separate credit computation is commonly referred to as the "university basic research credit
Page 73 - A capital asset generally means any property except (1) inventory, stock in trade, or property held primarily for sale to customers in the ordinary course of the taxpayer's trade or business, (2) depreciable or real property used in the taxpayer's trade or business, (3) specified literary or artistic property, (4) business accounts or notes receivable...
Page 149 - Mr. President, I ask unanimous consent to have printed in the Record at this point in...
Page 96 - The income concept used to show the distribution of tax expenditures by income class is adjusted gross income plus (1) tax-exempt interest, (2) employer contributions for health plans and life insurance, (3) employer share of FICA taxes, (4) workers...
Page 118 - MCCs entitle homebuyers to nonrefundable income tax credits for a specified percentage of interest paid on mortgage loans on their principal residences. Once issued, an MCC remains in effect as long as the loan remains outstanding and the residence being financed continues to be the certificate-recipient's principal residence.

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