| 1923 - 1092 Seiten
...the Phellis Case) as "a gain derived from capital, not a gain accruing to capital, nor a growth or increment of value in the investment, but a gain,...value, proceeding from the property, severed from capital, however invested, and coming in; that is, received or drawn by the claimant for his separate... | |
| 1925 - 822 Seiten
...in the Doyle case Here we have the essential matter: not a gain accruing to capital, not a growth or increment of value in the investment; but a gain,..."derived," that is, received or drawn by the recipient for his separate use, benefit, and disposal; that is income derived from property.1 In Eisner vs. Macomber,... | |
| Edward Sherwood Mead - 1920 - 504 Seiten
...— capital,' etc. Here we have the essential matter: not a gain accruing to capital, not a growth or increment of value in the investment; but a gain,...or employed, and coming in, being 'derived,' that ia, received or drawn by the recipient (the taxpayer) for his separate use, benefit and disposal;—... | |
| 1920 - 502 Seiten
...the fact that to be income such appreciation must be realized upon a closed transaction and be "... .something of exchangeable value, proceeding from...'derived,' that is, received or drawn by the recipient " An actual sale is practically the only answer to this description. Among economists and authorities... | |
| United States. Supreme Court - 1921 - 628 Seiten
...capital," etc. Here we have the essential matter: not a gain accruing to capital ; not a growth or increment of value in the Investment ; but a gain,...exchangeable value, proceeding from the property, »evered from the capital, however Invested or employed, and coming in, being "derived" — that is,... | |
| United States. Supreme Court - 1921 - 684 Seiten
...value of capital assets of the trust estate to be income because the gain or increase has not been "derived," that is, received or drawn by the recipient...taxpayer) for his separate use, benefit and disposal. Eisner v. Macomher, supra, 207, 211; 214, '215: In the case of a trustee who converts a capital asset... | |
| United States. Bureau of Internal Revenue - 1921 - 778 Seiten
...income states : Here we have the essential matter: Not a gain net-ruing to capital, not a ymtcth or increment of value in the investment, but a gain, a profit, something of exchangeable value prorreditifi from the property, xereretl from- the capital however invested or employed. * * *. Here... | |
| United States. Bureau of Internal Revenue - 1921 - 772 Seiten
...we have the essential matter: Not a gain net-ruing to capital, not a yrowth or increment of value iw the investment, but a gain, a profit, something of exchangeable value proceeding from the property, nerered from the capital however invested or employed. * * *. Here profit is made synonymous with income,... | |
| United States. Supreme Court - 1921 - 1362 Seiten
...— capital" etc. Here we have the essential matter: not a gain accruing to capital, not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value p'oceeding from the property, severed from the capital, however invested or employed, and coming in,... | |
| United States. Supreme Court - 1921 - 688 Seiten
...the trust estate to be income because the gain or increase has not been "derived," that is, teceived or drawn by the recipient (the taxpayer) for his separate use, benefit and disposal. Eisner v. Macomher, supra, 207, 211; 214, '215: In the case of a trustee who converts a capital asset... | |
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