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Byram V. United States
''Byram v. United States'', 705 F.2d 1418 (5th Cir. 1983) is a Fifth Circuit Court of Appeals decision that helps determine when a sale of land will result in a capital gain for purpose of the U.S. Federal income tax. Facts Taxpayer John D. Byram sold seven pieces of real estate in 1973. All transactions were initiated by the purchases; he did not subdivide the land, and spent minimal time and effort. From 1971–1973 Byram sold 22 parcels of real estate for a gross return of over $9 million and a net profit of $3.4 million. Issue Were the properties held for investment purposes (allowing capital gains treatment) and not primarily for sale to customers in the ordinary course of his trade or business? Holding The Court of Appeals for the Fifth Circuit affirmed the holding of the District Court. The properties were held for investment purposes and not primarily for sale to customers in the ordinary course of his trade or business and therefore warranted capital gains tr ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Court Of Appeals For The Fifth Circuit
The United States Court of Appeals for the Fifth Circuit (in case citations, 5th Cir.) is a federal court with appellate jurisdiction over the district courts in the following federal judicial districts: * Eastern District of Louisiana * Middle District of Louisiana * Western District of Louisiana * Northern District of Mississippi * Southern District of Mississippi * Eastern District of Texas * Northern District of Texas * Southern District of Texas * Western District of Texas The Fifth Circuit has 17 active judgeships, and is headquartered at the John Minor Wisdom United States Court of Appeals Building in New Orleans, Louisiana, with the clerk's office located at the F. Edward Hebert Federal Building in New Orleans. Originally, the Fifth Circuit also included the federal district courts in Alabama, Georgia, and Florida. In 1981, the district courts for those states were transferred to the newly created U.S. Court of Appeals for the Eleventh Circuit. History of ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
John Minor Wisdom
John Minor Wisdom (May 17, 1905 – May 15, 1999), one of the "Fifth Circuit Four", and a United States Republican Party, Republican from Louisiana, was a United States federal judge, United States circuit judge of the United States Court of Appeals for the Fifth Circuit during the 1950s and 1960s, when that court became known for a series of crucial decisions that advanced the goals of the Civil Rights Movement. At that time, the Fifth Circuit included not only Louisiana, Mississippi, and Texas (its jurisdiction since October 1, 1981), but also Alabama, Georgia (U.S. state), Georgia, Florida, and the Panama Canal Zone. Early life and education Wisdom was born on May 17, 1905, in New Orleans, Louisiana, and graduated from the Isidore Newman School. In 1925, he received an Bachelor of Arts, Artium Baccalaureus degree from Washington and Lee University in Lexington, Virginia, Lexington, Virginia. In 1929, he received a Bachelor of Laws from Tulane University Law School, graduating ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Thomas Gibbs Gee
Thomas Gibbs Gee (December 9, 1925 – October 25, 1994) was a United States circuit judge of the United States Court of Appeals for the Fifth Circuit. Education and career Born in Jacksonville, Florida, Gee received a Bachelor of Science degree from United States Military Academy in 1946. He was a lieutenant in the United States Army Air Corps in the aftermath of World War II, from 1946 to 1947, and then in the United States Air Force, from 1947 to 1950. He received a Bachelor of Laws from the University of Texas School of Law in 1953, and was in private practice in Houston, Texas from 1953 to 1954, and in Austin, Texas from 1954 to 1973. Federal judicial service On June 11, 1973, Gee was nominated by President Richard Nixon to a seat on the United States Court of Appeals for the Fifth Circuit vacated by Judge Joe McDonald Ingraham. Gee was confirmed by the United States Senate The United States Senate is the upper chamber of the United States Congress, with the Hous ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Thomas Morrow Reavley
Thomas Morrow Reavley (June 21, 1921 – December 1, 2020) was an American jurist, who was a Senior United States circuit judge of the United States Court of Appeals for the Fifth Circuit (and the oldest serving federal judge) at the time of his death. Education and career Reavley was born in Quitman, Texas. He received a Bachelor of Arts degree from the University of Texas in 1942. While at the University of Texas, he was a member of the Tejas Club. He was in the United States Navy from 1942 to 1946. As a naval lieutenant, Reavley drove President Franklin Roosevelt to Roosevelt’s meeting with Winston Churchill and Joseph Stalin at the Yalta Conference. After World War II, he received a Juris Doctor from Harvard Law School in 1948. He later received a Master of Laws from the University of Virginia School of Law in 1983. He was an assistant district attorney of Dallas, Texas from 1948 to 1949. He was in private practice of law in Nacogdoches, Texas from 1949 to 195 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Code
The Internal Revenue Code (IRC), formally the Internal Revenue Code of 1986, is the domestic portion of federal statutory tax law in the United States, published in various volumes of the United States Statutes at Large, and separately as Title 26 of the United States Code (USC). It is organized topically, into subtitles and sections, covering income tax in the United States, payroll taxes, estate taxes, gift taxes, and excise taxes; as well as procedure and administration. The Code's implementing federal agency is the Internal Revenue Service. Origins of tax codes in the United States Prior to 1874, U.S. statutes (whether in tax law or other subjects) were not codified. That is, the acts of Congress were not separately organized and published in separate volumes based on the subject matter (such as taxation, bankruptcy, etc.). Codifications of statutes, including tax statutes, undertaken in 1873 resulted in the Revised Statutes of the United States, approved June 22, 1874, eff ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Fifth Circuit Court Of Appeals
The United States Court of Appeals for the Fifth Circuit (in case citations, 5th Cir.) is a federal court with appellate jurisdiction over the district courts in the following federal judicial districts: * Eastern District of Louisiana * Middle District of Louisiana * Western District of Louisiana * Northern District of Mississippi * Southern District of Mississippi * Eastern District of Texas * Northern District of Texas * Southern District of Texas * Western District of Texas The Fifth Circuit has 17 active judgeships, and is headquartered at the John Minor Wisdom United States Court of Appeals Building in New Orleans, Louisiana, with the clerk's office located at the F. Edward Hebert Federal Building in New Orleans. Originally, the Fifth Circuit also included the federal district courts in Alabama, Georgia, and Florida. In 1981, the district courts for those states were transferred to the newly created U.S. Court of Appeals for the Eleventh Circuit. History of ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Capital Gain
Capital gain is an economic concept defined as the profit earned on the sale of an asset which has increased in value over the holding period. An asset may include tangible property, a car, a business, or intangible property such as shares. A capital gain is only possible when the selling price of the asset is greater than the original purchase price. In the event that the purchase price exceeds the sale price, a capital loss occurs. Capital gains are often subject to taxation, of which rates and exemptions may differ between countries. The history of capital gain originates at the birth of the modern economic system and its evolution has been described as complex and multidimensional by a variety of economic thinkers. The concept of capital gain may be considered comparable with other key economic concepts such as profit and rate of return, however its distinguishing feature is that individuals, not just businesses, can accrue capital gains through everyday acquisition a ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Income Tax In The United States
Income taxes in the United States are imposed by the federal government, and most states. The income taxes are determined by applying a tax rate, which may increase as income increases, to taxable income, which is the total income less allowable deductions. Income is broadly defined. Individuals and corporations are directly taxable, and estates and trusts may be taxable on undistributed income. Partnerships are not taxed (with some exceptions in the case of Federal income taxation), but their partners are taxed on their shares of partnership income. Residents and citizens are taxed on worldwide income, while nonresidents are taxed only on income within the jurisdiction. Several types of credits reduce tax, and some types of credits may exceed tax before credits. An alternative tax applies at the federal and some state levels. In the United States, the term "payroll tax" usually refers to FICA taxes that are paid to fund Social Security and Medicare, while "income tax" re ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Real Estate
Real estate is property consisting of land and the buildings on it, along with its natural resources such as crops, minerals or water; immovable property of this nature; an interest vested in this (also) an item of real property, (more generally) buildings or housing in general."Real estate": Oxford English Dictionary online: Retrieved September 18, 2011 In terms of law, ''real'' is in relation to land property and is different from personal property while ''estate'' means the "interest" a person has in that land property. Real estate is different from personal property, which is not permanently attached to the land, such as vehicles, boats, jewelry, furniture, tools and the rolling stock of a farm. In the United States, the transfer, owning, or acquisition of real estate can be through business corporations, individuals, nonprofit corporations, fiduciaries, or any legal entity as seen within the law of each U.S. state. History of real estate The natural right of a person t ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
1983 In United States Case Law
The year 1983 saw both the official beginning of the Internet and the first mobile cellular telephone call. Events January * January 1 – The migration of the ARPANET to TCP/IP is officially completed (this is considered to be the beginning of the true Internet). * January 24 – Twenty-five members of the Red Brigades are sentenced to life imprisonment for the 1978 murder of Italian politician Aldo Moro. * January 25 ** High-ranking Nazi war criminal Klaus Barbie is arrested in Bolivia. ** IRAS is launched from Vandenberg AFB, to conduct the world's first all-sky infrared survey from space. February * February 2 – Giovanni Vigliotto goes on trial on charges of polygamy involving 105 women. * February 3 – Prime Minister of Australia Malcolm Fraser is granted a double dissolution of both houses of parliament, for elections on March 5, 1983. As Fraser is being granted the dissolution, Bill Hayden resigns as leader of the Australian Labor Party, and in the subsequent lead ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Taxation And Revenue Case Law
United may refer to: Places * United, Pennsylvania, an unincorporated community * United, West Virginia, an unincorporated community Arts and entertainment Films * ''United'' (2003 film), a Norwegian film * ''United'' (2011 film), a BBC Two film Literature * ''United!'' (novel), a 1973 children's novel by Michael Hardcastle Music * United (band), Japanese thrash metal band formed in 1981 Albums * ''United'' (Commodores album), 1986 * ''United'' (Dream Evil album), 2006 * ''United'' (Marvin Gaye and Tammi Terrell album), 1967 * ''United'' (Marian Gold album), 1996 * ''United'' (Phoenix album), 2000 * ''United'' (Woody Shaw album), 1981 Songs * "United" (Judas Priest song), 1980 * "United" (Prince Ital Joe and Marky Mark song), 1994 * "United" (Robbie Williams song), 2000 * "United", a song by Danish duo Nik & Jay featuring Lisa Rowe Television * ''United'' (TV series), a 1990 BBC Two documentary series * ''United!'', a soap opera that aired on BBC One from 1965-19 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Property Case Law
United may refer to: Places * United, Pennsylvania, an unincorporated community * United, West Virginia, an unincorporated community Arts and entertainment Films * ''United'' (2003 film), a Norwegian film * ''United'' (2011 film), a BBC Two film Literature * ''United!'' (novel), a 1973 children's novel by Michael Hardcastle Music * United (band), Japanese thrash metal band formed in 1981 Albums * ''United'' (Commodores album), 1986 * ''United'' (Dream Evil album), 2006 * ''United'' (Marvin Gaye and Tammi Terrell album), 1967 * ''United'' (Marian Gold album), 1996 * ''United'' (Phoenix album), 2000 * ''United'' (Woody Shaw album), 1981 Songs * "United" (Judas Priest song), 1980 * "United" (Prince Ital Joe and Marky Mark song), 1994 * "United" (Robbie Williams song), 2000 * "United", a song by Danish duo Nik & Jay featuring Lisa Rowe Television * ''United'' (TV series), a 1990 BBC Two documentary series * ''United!'', a soap opera that aired on BBC One from 1965-19 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
