Warren Jones Co. V. Commissioner
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Warren Jones Co. V. Commissioner
''Warren Jones Company v. Commissioner of Internal Revenue'', 524 F.2d 788 (9th Cir. 1975) was a taxation decision by the United States Court of Appeals for the Ninth Circuit. It reversed a US Tax Court decision that held that "the fair market value of a real estate contract did not constitute an amount realized by the taxpayer in the taxable year of sale under Internal Revenue Code § 1001(b)." The Court of Appeals held "that the real estate had a certain fair market value that was ascertainable and that the taxpayer had to include that fair market value to determine the amount realized under § 1001(b)." Background Taxpayer, the Warren Jones Company, entered into a real estate contract to sell an apartment building for $153,000 on May 27, 1968 to Bernard and Jo An Storey. On June 15, 1968, the sale closed and the Storeys paid taxpayer $20,000 in cash and took possession of the apartment building. The contract then required the Storeys to pay the taxpayer $1,000 per month, plus ...
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United States Court Of Appeals For The Ninth Circuit
The United States Court of Appeals for the Ninth Circuit (in case citations, 9th Cir.) is the U.S. federal court of appeals that has appellate jurisdiction over the U.S. district courts in the following federal judicial districts: * District of Alaska * District of Arizona * Central District of California * Eastern District of California * Northern District of California * Southern District of California * District of Hawaii * District of Idaho * District of Montana * District of Nevada * District of Oregon * Eastern District of Washington * Western District of Washington The Ninth Circuit also has appellate jurisdiction over the territorial courts for the District of Guam and the District of the Northern Mariana Islands. Additionally, it sometimes handles appeals that originate from American Samoa, which has no district court and partially relies on the District of Hawaii for its federal cases.https://www.gao.gov/products/GAO-08-1124T GAO (U.S. Government Accountabil ...
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Commissioner Of Internal Revenue
The Commissioner of Internal Revenue is the head of the Internal Revenue Service (IRS), an agency within the United States Department of the Treasury. The office of Commissioner was created by Congress as part of the Revenue Act of 1862. Section 7803 of the Internal Revenue Code provides for the appointment of a Commissioner of Internal Revenue to administer and supervise the execution and application of the internal revenue laws. The Commissioner is appointed by the President of the United States, with the consent of the U.S. Senate, for a five-year term. Douglas O’Donnell became the current and Acting Commissioner of Internal Revenue after Charles P. Rettig's term as Commissioner ended on November 12, 2022. Responsibilities The Commissioner's duties include administering, managing, conducting, directing, and supervising "the execution and application of the internal revenue laws or related statutes and tax conventions to which the United States is a party" and advising the ...
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United States Court Of Appeals For The Ninth 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 ...
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Thomson Reuters
Thomson Reuters Corporation ( ) is a Canadian multinational media conglomerate. The company was founded in Toronto, Ontario, Canada, where it is headquartered at the Bay Adelaide Centre. Thomson Reuters was created by the Thomson Corporation's purchase of the British company Reuters Group in April 2008. It is majority-owned by The Woodbridge Company, a holding company for the Thomson family. History Thomson Corporation The forerunner of the Thomson company was founded by Roy Thomson in 1934 in Ontario, as the publisher of ''The Timmins Daily Press''. In 1953, Thomson acquired the ''Scotsman'' newspaper and moved to Scotland the following year. He consolidated his media position in Scotland in 1957, when he won the franchise for Scottish Television. In 1959, he bought the Kemsley Group, a purchase that eventually gave him control of the '' Sunday Times''. He separately acquired the ''Times'' in 1967. He moved into the airline business in 1965, when he acquired Britanni ...
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Burnet V
Burnet may refer to: Life forms * Burnet moth, the Zygaenidae family of diurnal moths ** Six-spot burnet (''Z. filipendulae''), a red-spotted species endemic to Europe and Anatolia * Burnet (plant), the perennial genus ''Sanguisorba'' **Salad burnet (''S. minor''), a herb with edible, ferny leaves * Burnet saxifrage or "lesser burnet", an unrelated plant species of similar appearance * Acaena, a herb genus including southern South America's "greater burnet" and "lesser burnet" Places * Burnet, Texas, United States ** Burnet County, Texas Other uses * HMS ''Burnet'' (K348), a British-commissioned warship in WWII * Professor Burnet, a ''Pokémon'' character People named ''Burnet'' * Burnet (surname), people with the surname * Burnet Reading (1749–1838), English engraver See also * Burnett (other) * Burnette (other) Burnette could be: * an incorrect spelling of "brunette". * Billy Burnette (born 1953), American guitarist * Dorsey Burnette (1932– ...
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US Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point of federal law. It also has original jurisdiction over a narrow range of cases, specifically "all Cases affecting Ambassadors, other public Ministers and Consuls, and those in which a State shall be Party." The court holds the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution. It is also able to strike down presidential directives for violating either the Constitution or statutory law. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but has ruled that it does not have power to decide non-justiciable political questions. Established by Article Three of the United States Consti ...
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Cash Method Of Accounting
The cash method of accounting, also known as cash-basis accounting, cash receipts and disbursements method of accounting or cash accounting (the EU VAT directive vocabulary Article 226) records revenue when cash is received, and expenses when they are paid in cash. As a basis of accounting, this is in contrast to the alternative accrual method which records income items when they are ''earned'' and records deductions when expenses are ''incurred'' regardless of the flow of cash. Cash method of accounting in the United States (GAAP) Use in contract accounting The cash method of accounting has historically been one of the four methods of recognizing revenues and profits on contracts, the other ones being the accrual method, the completed-contract method and the percentage-of-completion methods. Since the approval by Congress of the Tax Reform Act of 1986, the cash method could not longer be used for C corporations, partnerships in which one or more partners are C Corporations, t ...
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Cash Equivalence Doctrine
The Doctrine of Cash Equivalence states that the U.S. Federal income tax law treats certain non-cash payment transactions like cash payment transactions for federal income tax purposes. The doctrine is used most often for deciding when cash method (as opposed to accrual method) taxpayers are to include certain non-cash income items. Another doctrine often used when trying to determine the timing of the inclusion of income is the constructive receipt doctrine. Most individuals begin as cash method taxpayers because their first form of bookkeeping is a checkbook. In contrast, some businesses start as accrual method taxpayers because businesses use different rules for recording income and expenditures. The Internal Revenue Code (IRC) § 446(a) states, however, that " xable income shall be computed under the method of accounting on the basis which the taxpayer regularly computes his income in keeping his books." One of the major advantages to the cash method of accounting is the abi ...
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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 ...
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Long Term Capital Gains Tax
A capital gains tax (CGT) is the tax on profits realized on the sale of a non-inventory asset. The most common capital gains are realized from the sale of stocks, bonds, precious metals, real estate, and property. Not all countries impose a capital gains tax and most have different rates of taxation for individuals versus corporations. Countries that do not impose a capital gains tax include Bahrain, Barbados, Belize, Cayman Islands, Isle of Man, Jamaica, New Zealand, Sri Lanka, Singapore, and others. In some countries, such as New Zealand and Singapore, professional traders and those who trade frequently are taxed on such profits as a business income. In Sweden, the Investment Savings Account (ISK – ''Investeringssparkonto'') was introduced in 2012 in response to a decision by Parliament to stimulate saving in funds and equities. There is no tax on capital gains in ISKs; instead, the saver pays an annual standard low rate of tax. Fund savers nowadays mainly choose to save in ...
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Installment Sale
In United States income tax law, an installment sale is generally a "disposition of property where at least 1 loan payment is to be received after the close of the taxable year in which the disposition occurs." The term "installment sale" does not include, however, a "dealer disposition" (as defined in the statute) or, generally, a sale of inventory. The installment method of accounting provides an exception to the general principles of income recognition by allowing a taxpayer to defer the inclusion of income of amounts that are to be received from the disposition of certain types of property until payment in cash or cash equivalents is received. The installment method defers the recognition of income when compared with both the cash and accrual methods of accounting. Under the cash method, the taxpayer would recognize the income when it is received, including the entire sum paid in the form of a negotiable note.Overview of Issues Relating to the Modification of the Installmen ...
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