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Section 61 of the Internal Revenue Code (IRC 61, 26 U.S.C. § 61) defines "gross income," the starting point for determining which items of income are taxable for federal income tax purposes in the United States. Section 61 states that "[e]xcept as otherwise provided in this subtitle, gross income means all income from whatever source derived
First, there can be no surprises; that is, the conditions for receipt must be stated clearly and the beneficiary must be aware of those conditions and their consequences. Second, the conditions imposed must be related to the spending in question. Last, the incentive must not be so significant as to turn cooperation into coercion.
In the Joslin case, the United States Court of Appeals for the Tenth Circuit ruled that under 26 U.S.C. § 61 and 26 C.F.R. 1.61-2(d)(1), a taxpayer who bargains to be paid for his services in legal tender (in this case, silver dollar coins) must report the income at the fair market value (numismatic value), and not at the lower face value. [72]
Davis v. Commissioner, T.C. Memo. 1978-12 (1978), [1] was a case in which the United States Tax Court held that in order to have constructive receipt, a taxpayer must have notice of the attempt to transfer funds to the taxpayer.
The full text of the IRS regulation defining constructive receipt states as follows: [2] 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 ...
The concurrent use proceeding resumed, and in 1976, the United States Court of Customs and Patent Appeals awarded the Myrtle Beach hotel a federal trademark registration. [21] Even where a concurrent use registration is issued, the parties may eventually come to an agreement under which one party will surrender its registration.
To amend title 11, United States Code, to exempt for a limited period, from the application of the means-test presumption of abuse under chapter 7, qualifying members of reserve components of the Armed Forces and members of the National Guard who, after September 11, 2001, are called to active duty or to perform a homeland defense activity for ...
IDR's are based on the original American depositary receipts that were first introduced in 1927 in the US.. The Ministry of Corporate Affairs of the Government of India, using section 642 read with section 605A had prescribed the Companies (Issue of Indian Depository Receipts) Rules, 2004 (IDR Rules) vide notification number GSR 131(E) dated February 23, 2004.