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Salvatore V. Commissioner
''Salvatore v. Commissioner'' is an opinion from the United States Tax Court that holds that a taxpayer cannot avoid paying taxes on the sale of property by first conveying that property to someone else. This opinion was later affirmed by the United States Court of Appeals for the Second Circuit. This case outlines some limitations on the "fruit-and-tree" metaphor established in ''Lucas v. Earl'', 281 U.S. 111 (1930) and further developed in ''Helvering v. Horst'', 311 U.S. 112 (1940). Decided in 1970, the case arose when a taxpayer tried to avoid paying Capital gains tax in the United States, capital gains tax from sale of property by giving a share in that property to her children. She then paid a gift tax, which is significantly less than the tax on the gain would have been if she had not given a share to her children. Background Prior to his death on October 7, 1948, Susie Salvatore's husband owned and operated a gas station in Greenwich, Connecticut. Upon his death, his e ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Tax Court
The United States Tax Court (in case citations, T.C.) is a Federal judiciary of the United States, federal trial court court of record, of record established by US Congress, Congress under Article One of the United States Constitution, Article I of the Constitution of the United States, 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 litigation, litigate tax matters in a variety of legal settings, outside of Bankruptcy in the United States, 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 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Warranty Deed
A warranty deed is a type of deed where the grantor (seller) guarantees that they hold clear title to a piece of real estate and has a right to sell it to the grantee (buyer), in contrast to a quitclaim deed, where the seller does not guarantee that they hold title to a piece of real estate. A ''general'' warranty deed protects the grantee against title defects arising at any point in time, extending back to the property's origins. A ''special'' warranty deed protects the grantee only against title defects arising from the actions or omissions of the grantor. Covenants for title A warranty deed can include six traditional forms of covenants for title, sometimes known as the English covenants of title. Those six traditional forms of covenants can be broken down into two categories: ''present covenants'' and ''future covenants''. ;Present covenants * Covenant of seisin: "A covenant of seisin or good right to convey." * Covenant of right to convey: Covenants that represent ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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 * ''The United'' (film), an unreleased Arabic-language 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 * "United (Who We Are)", a song by XO-IQ, featured in the television serie ... [...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 * ''The United'' (film), an unreleased Arabic-language 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 * "United (Who We Are)", a song by XO-IQ, featured in the television ser ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Estate Of Stranahan V
Estate or The Estate may refer to: Law * Estate (law), a term in common law for a person's property, entitlements and obligations * Estates of the realm, a broad social category in the histories of certain countries. ** The Estates, representative bodies of the estates of the realm *** Estates General, a supra-regional gathering of representatives of the estates of the realm * Estate in land * Estate (land), the grounds and tenancies (such as farms, housing, woodland, parkland) associated with a very large property ** Fortified estate, a housing estate surrounded by a wall with gate entrance/checkpoint. ** Housing estate, a group of houses built as a single development. ** Industrial estate (office park) and trading estate; property planned and sub-let for industrial and commercial use. ** Real estate or real property ***Estate agent or real estate agent * Literary estate, the intellectual property of a deceased author, or the executor thereof Automobiles and technology * Estate ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Commissioner V
A commissioner (commonly abbreviated as Comm'r) is, in principle, a member of a commission or an individual who has been given a Wiktionary: commission, commission (official charge or authority to do something). In practice, the title of commissioner has evolved to include a variety of senior officials, often sitting on a specific commission. In particular, the commissioner frequently refers to senior police or government officials. A high commissioner is equivalent to an ambassador, originally between the United Kingdom and the Dominions and now between all Commonwealth states, whether Commonwealth realms, republics in the Commonwealth of Nations, republics or countries having a monarch other than that of the realms. The title is sometimes given to senior officials in the private sector; for instance, many North American sports leagues. There is some confusion between commissioners and commissary, commissaries because other European languages use the same word for both. Therefore ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Supreme Court Of The United States
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 Federal tribunals in the United States, U.S. federal court cases, and over State court (United States), state court cases that turn on questions of Constitution of the United States, U.S. constitutional or Law of the United States, federal law. It also has Original jurisdiction of the Supreme Court of the United States, 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." In 1803, the Court asserted itself the power of Judicial review in the United States, judicial review, the ability to invalidate a statute for violating a provision of the Constitution via the landmark case ''Marbury v. Madison''. It is also able to strike down presidential directives for violating either the Constitution or s ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Legal Precedent
Precedent is a judicial decision that serves as an authority for courts when deciding subsequent identical or similar cases. Fundamental to common law legal systems, precedent operates under the principle of ''stare decisis'' ("to stand by things decided"), where past judicial decisions serve as case law to guide future rulings, thus promoting consistency and predictability. Precedent is a defining feature that sets common law systems apart from civil law systems. In common law, precedent can either be something courts must follow (binding) or something they can consider but do not have to follow (persuasive). Civil law systems, in contrast, are characterized by comprehensive codes and detailed statutes, with no emphasis on precedent, and where judges primarily focus on fact-finding and applying codified law. Courts in common law systems rely heavily on case law, which refers to the collection of precedents and legal principles established by previous judicial decisions on s ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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 United States Congress, 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 United States Senate , U.S. Senate, for a five-year term. On December 4, 2024, President-elect Donald Trump announced his intention to nominate Billy Long to serve as Commissioner of the Internal Revenue Service. Daniel Werfel was the latest Commissioner of Internal Revenue, having been sworn in on March 13, 2023. Werfel is the 50th Commissioner to serve in the position since it was created. He announced his resignation Friday, January 1 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Ordinary Income
Under the United States Internal Revenue Code, the ''type'' of income is defined by its character. Ordinary income is usually characterized as income other than long-term capital gains. Ordinary income can consist of income from wages, salaries, tips, commissions, bonuses, and other types of compensation from employment, interest, dividends, or net income from a sole proprietorship, partnership or LLC. Rents and royalties, after certain deductions, depreciation or depletion allowances, and gambling winnings are also treated as ordinary income. A "short term capital gain", or gain on the sale of an asset held for less than one year of the capital gains holding period, is taxed as ordinary income. Ordinary income stands in contrast to capital gain, which is defined as gain from the sale or exchange of a capital asset. A personal residence is a capital asset to the homeowner. By contrast, a land developer who had many houses for sale on many lots would treat each of those ... [...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
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 jurisdictio ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
