Veit V. Commissioner
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Veit V. Commissioner
The United States Tax Court decided two cases, both titled ''Veit v. Commissioner'', in 1947 and 1949. These cases deal with the doctrine of constructive receipt For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has received gross income. A taxpayer is subject to tax in the current year if he or she has unfettered control in determining wh .... In both cases, the taxpayer was an executive vice president of a corporation. He was entitled to a fixed salary plus a bonus of 10% of the corporation's profits for the years 1939 and 1940, with the bonus to be paid in 1941. However, his contract was revised in November 1940 to provide that the bonus from the 1939 profits would be paid in 1941, and the bonus from the 1940 profits would be paid in 1942. In ''Veit I'', the first of the two cases, the IRS objected to the new contract, claiming that the bonus from the 1940 profits was constructively received in 1941 and thus s ...
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United States Tax Court
The United States Tax Court (in case citations, T.C.) is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 of which provides (in part) that the Congress has the power to "constitute Tribunals inferior to the supreme Court". The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule" ...
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Luther Alexander Johnson
Luther Alexander Johnson (October 29, 1875 – June 6, 1965) was a United States Congressman from the U.S. state of Texas. Early years Luther was born in Corsicana, Texas, where he attended the public schools. He received his L.L.B. in 1896 from Cumberland University in Lebanon, Tennessee, and was admitted to the Bar association the same year. He commenced practice in Corsicana and was attorney for Central Texas Grocery Company and The Royall Coffee Company. He was a prosecuting attorney of Navarro County from 1898 to 1902 and district attorney of the thirteenth judicial district of Texas from 1904 to 1910. Congress He served as a delegate to the Democratic National Convention in 1916 and as chairman of the Democratic State convention in 1920. Johnson was elected as a Democrat to the Sixty-eighth and to the eleven succeeding Congresses and served from March 4, 1923, until his resignation on July 17, 1946. A confidential 1943 analysis of the House Foreign Affairs Committee b ...
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Constructive Receipt
For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has received gross income. A taxpayer is subject to tax in the current year if he or she has unfettered control in determining when items of income will or should be paid.Treas. Reg. § 1.451-2(a). Unlike actual receipt, constructive receipt does not require physical possession of the item of income in question. Background The full text of the IRS regulation defining constructive receipt states as follows: ''“Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subjec ...
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Constructive Receipt
For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has received gross income. A taxpayer is subject to tax in the current year if he or she has unfettered control in determining when items of income will or should be paid.Treas. Reg. § 1.451-2(a). Unlike actual receipt, constructive receipt does not require physical possession of the item of income in question. Background The full text of the IRS regulation defining constructive receipt states as follows: ''“Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subjec ...
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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 ...
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United States Tax Court 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 ...
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1947 In United States Case Law
It was the first year of the Cold War, which would last until 1991, ending with the dissolution of the Soviet Union. Events January * January–February – Winter of 1946–47 in the United Kingdom: The worst snowfall in the country in the 20th century causes extensive disruption of travel. Given the low ratio of private vehicle ownership at the time, it is mainly remembered in terms of its effects on the railway network. * January 1 - The Canadian Citizenship Act comes into effect. * January 4 – First issue of weekly magazine ''Der Spiegel'' published in Hanover, Germany, edited by Rudolf Augstein. * January 10 – The United Nations adopts a resolution to take control of the free city of Trieste. * January 15 – Elizabeth Short, an aspiring actress nicknamed the "Black Dahlia", is found brutally murdered in a vacant lot in Los Angeles; the mysterious case is never solved. * January 16 – Vincent Auriol is inaugurated as president of France. * January 19 – Ferry ...
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