 | United States. Tax Court - Law reports, digests, etc - 1967 - 786 pages
...1950), acq. 1952-2 CB 3, we stated at page 1077: tbe Commissioner has always recognized, as Indeed be must to stay within the Constitution, that the cost...arrive at gross income. No more than gross income can lie subjected to income tax upon any theory. * * * No authority has been cited for denying to this... | |
 | United States. Tax Court - Law reports, digests, etc - 1960 - 1484 pages
...provision for the cost of goods sold, but the Commissioner has always recognized, as Indeed he must stay within the Constitution, that the cost of goods...income. No more than gross Income can be subjected to income tax upon any theory. * * * Again, in 1 Mortens, Law of Federal Income Taxation sec. 5.06,... | |
 | United States. Tax Court - Taxation - 1967 - 748 pages
...(1948), nonacq. 1949-1 CB 6, appeal dismissed (CA 5, 1950), acq. 1952-2 CB 3, we stated at page 1077: the Commissioner has always recognized, as Indeed...of goods sold must be deducted from gross receipts lu order to arrive at gross income. A'o more than gross income can be subjected to income tan upon... | |
 | United States. Tax Court - Taxation - 1978 - 1134 pages
...the courts have simply recognized that no more than gross income can be subjected to income tax and that the cost of goods sold must be deducted from gross receipts in order to arrive at gross income, the starting point for an income tax. Sullenger v. Commissioner, 11 TC 1076 (1948); Hofferbert v. Anderson... | |
 | United States. Tax Court - Taxation - 1978 - 1146 pages
...the courts have simply recognized that no more than gross income can be subjected to income tax and that the cost of goods sold must be deducted from gross receipts in order to arrive at gross income, the starting point for an income tax. Sullenger v. Commissioner, 11 TC 1076 (1948); Hofferbert v. Anderson... | |
 | United States. Congress. House. Committee on Ways and Means - Fiscal policy - 1996 - 304 pages
...Price Administration, a World War II agency, made no provision for the deduction of the cost of goods sold: "but the Commissioner has always recognized,...income. No more than gross income can be subjected to income tax upon any theory. The income from a business which is wholly illegal was held subject... | |
 | United States. Tax Court - Law reports, digests, etc - 1964 - 1220 pages
...receipts as distinguished from gross income, pointing out that in Lela Sullenger, supra, we stated that the Commissioner has always recognized, "as indeed...gross receipts in order to arrive at gross income." Petitioners equate taxing receipts to disallowing the loss as computed by subtracting from the selling... | |
 | United States. Tax Court - Law reports, digests, etc - 1960 - 1512 pages
...provision for the cost of goods sold, but the Commissioner has always recognized, as Indeed he must stay within the Constitution, that the cost of goods...sold must be deducted from gross receipts in order to arriTe at gross Income. No more than gross income can be subjected to Income Us upon any theory. *... | |
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Section 23 makes no provision for the cost of goods sold but the Commissioner has always recognized, as Indeed he must to stay within the Constitution, that the cost or goods sold must be deducted from gross receipts In order to arrive at gross income.... 