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Farid-Es-Sultaneh V. Commissioner
''Farid-Es-Sultaneh v. Commissioner'', 160 F.2d 812 (2d Cir. 1947) is a United States federal income tax case. It is notable (and thus appears frequently in law school casebooks) for the following holding: * Appreciated property, transferred to a wife pursuant to an antenuptial agreement, was not a gift, but was consideration for which she sold her inchoate marital rights. * This applies the general rule, that a taxpayer recognizes a gain on the transfer of appreciated property in satisfaction of a legal obligation. * Therefore, the property's basis in her hands was not a "carryover" (gift) basis from her husband. Instead, the court set its basis at its fair market value. Facts The taxpayer-wife sold stock which she had received from her husband, S. S. Kresge, pursuant to an antenuptial agreement, under which she accepted the shares in consideration for surrendering all marital property rights in her husband's estate. (When they married, she was 32 years old; he was 57 years ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Court Of Appeals For The Second Circuit
The United States Court of Appeals for the Second Circuit (in case citations, 2d Cir.) is one of the thirteen United States Courts of Appeals. Its territory comprises the states of Connecticut, New York and Vermont. The court has appellate jurisdiction over the district courts in the following districts: * District of Connecticut * Eastern District of New York * Northern District of New York * Southern District of New York * Western District of New York * District of Vermont The Second Circuit has its clerk's office and hears oral arguments at the Thurgood Marshall United States Courthouse at 40 Foley Square in Lower Manhattan. Due to renovations at that building, from 2006 until early 2013, the court temporarily relocated to the Daniel Patrick Moynihan United States Courthouse across Pearl Street from Foley Square; certain court offices temporarily relocated to the Woolworth Building at 233 Broadway. Because the Second Circuit includes New York City, it has long been one ... [...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] |
United States Court Of Appeals For The Second Circuit Cases
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 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 V
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] |
Corporate Stocks
In finance, stock (also capital stock) consists of all the shares by which ownership of a corporation or company is divided.Longman Business English Dictionary: "stock - ''especially AmE'' one of the shares into which ownership of a company is divided, or these shares considered together" "When a company issues shares or stocks ''especially AmE'', it makes them available for people to buy for the first time." (Especially in American English, the word "stocks" is also used to refer to shares.) A single share of the stock means fractional ownership of the corporation in proportion to the total number of shares. This typically entitles the shareholder (stockholder) to that fraction of the company's earnings, proceeds from liquidation of assets (after discharge of all senior claims such as secured and unsecured debt), or voting power, often dividing these up in proportion to the amount of money each stockholder has invested. Not all stock is necessarily equal, as certain classes ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Cost Basis
Basis (or cost basis), as used in United States tax law, is the original cost of property, adjusted for factors such as depreciation. When property is sold, the taxpayer pays/(saves) taxes on a capital gain/(loss) that equals the amount realized on the sale minus the sold property's basis. Cost basis is needed because tax is due based on the gain in value of an asset. For example, if a person buys a rock for $20, and sells the same rock for $20, there is no tax, since there is no profit. If, however, that person buys a rock for $20 and then sells the same rock for $25, then there is a capital gain on the rock of $5, which is thus taxable. The purchase price of $20 is analogous to cost of sales. Typically, capital gains tax is due only when an asset is sold. However the rules for this are very complicated. If tax is paid because the value has increased, the new value will be the cost basis for any future tax. Internal Revenue Service (IRS) Publication 551 contains the IRS's defi ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Income Tax
An income tax is a tax imposed on individuals or entities (taxpayers) in respect of the income or profits earned by them (commonly called taxable income). Income tax generally is computed as the product of a tax rate times the taxable income. Taxation rates may vary by type or characteristics of the taxpayer and the type of income. The tax rate may increase as taxable income increases (referred to as graduated or progressive tax rates). The tax imposed on companies is usually known as corporate tax and is commonly levied at a flat rate. Individual income is often taxed at progressive rates where the tax rate applied to each additional unit of income increases (e.g., the first $10,000 of income taxed at 0%, the next $10,000 taxed at 1%, etc.). Most jurisdictions exempt local charitable organizations from tax. Income from investments may be taxed at different (generally lower) rates than other types of income. Credits of various sorts may be allowed that reduce tax. Some jurisdicti ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Revenue Act Of 1936
The Revenue Act of 1936, (June 22, 1936), established an "undistributed profits tax" on corporations in the United States . It was signed into law by President Franklin D. Roosevelt. The act was applicable to incomes for 1936 and thereafter. Roosevelt sought additional permanent revenue of $620,000,000 and temporary revenue of $517,000,000. To secure the permanent revenue he suggested the substitution of a tax on undistributed earnings of corporations. Individual rates were raised only on the very rich (that is, income over $5 million a year.). Roy G. Blakey, and Gladys C. Blakey. "The Revenue Act of 1936." ''American Economic Review'' (1936): 466-48online See also * Revenue Act of 1935, which raised taxes on high incomes Tax on corporations Normal tax A Normal Tax was levied on the net income of corporations as shown in the following table. Surtax on undistributed profits A Surtax was levied on corporations on "undistributed profits", i.e. profits not paid out in div ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Fair Market Value
The fair market value of property is the price at which it would change hands between a willing and informed buyer and seller. The term is used throughout the Internal Revenue Code, as well as in bankruptcy laws, in many state laws, and by several regulatory bodies. In litigation in many jurisdictions in the United States the fair market value is determined at a hearing. In certain jurisdictions, the courts are required to hold fair market hearings, even if the borrowers or the loans guarantors waived their rights to such a hearing in the loan documents. Definition United States The fair market value is the price at which property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts. ''United States v. Cartwright'', 411 U. S. 546, 93 S. Ct. 1713, 1716-17, 36 L. Ed. 2d 528, 73-1 U.S. Tax Cas. ( CCH) ¶ 12,926 (1973) (quoting from U.S. Treasury regulations relat ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Taxpayer
A taxpayer is a person or organization (such as a company) subject to pay a tax. Modern taxpayers may have an Taxpayer Identification Number, identification number, a reference number issued by a government to Citizenship, citizens or Company, firms. The term "taxpayer" generally characterizes one who pays taxes. A taxpayer is an individual or entity that is obligated to make Payment, payments to Municipality, municipal or government Revenue service, taxation-agencies. Taxes can exist in the form of Income tax, income taxes and/or Property tax, property taxes imposed on owners of real property (such as homes and vehicles), along with many other forms. People may pay taxes when they pay for goods and services which are taxed. The term "taxpayer" often refers to the workforce of a country which pays for government systems and projects through taxation. The taxpayers' money becomes part of the Government spending, public funds, which comprise all money spent or invested by governmen ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Thomas Walter Swan
Thomas Walter Swan (December 20, 1877 – July 13, 1975) was a United States circuit judge of the United States Court of Appeals for the Second Circuit. Education and career Born in Norwich, Connecticut Swan received an Artium Baccalaureus degree from Yale University in 1900. He received a Bachelor of Laws from Harvard Law School in 1903. He was in private practice of law in Chicago, Illinois from 1903 to 1916. He was a lecturer in law at the University of Chicago from 1903 to 1904, and in 1908. He was Dean and Professor of Law at Yale Law School from 1916 to 1927. Federal judicial service Swan was nominated by President Calvin Coolidge on December 15, 1926, to a seat on the United States Court of Appeals for the Second Circuit vacated by Judge Henry Wade Rogers. He was confirmed by the United States Senate on December 22, 1926, and received his commission the same day. He served as Chief Judge and as a member of the Judicial Conference of the United States from 1951 to 19 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
