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" 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 proceeding from the property, severed from the capital however invested or employed,... "
Cases Decided in the United States Court of Claims ... with Report of ... - Page 513
by United States. Court of Claims, Audrey Bernhardt - 1958
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Cases on Federal Taxation, Volume 1

Joseph Henry Beale, Roswell Foster Magill - 1926 - 744 pages
...be in the hands of the taxpayer, as said in Eisner v. Macomber, supra : "Something of exchangeable value proceeding from the property, severed from the...from property. Nothing else answers the description." Certainly there was no conversion of capital to bring the transaction in the case at bar within the...
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National University Law Review, Volume 6

1926 - 666 pages
...profit, something of exchangeable value, proceeding from the property, severed from the capital, however, received or drawn by the recipient (the taxpayer)...from property, nothing else answers the description." " and that is the "legal concept" of "income" far better expressed than it is likely to be by any text...
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Reports of the U.S. Board of Tax Appeals, Volume 1

United States. Board of Tax Appeals - 1926 - 1508 pages
...not a growth or increment of value in the Investment; but a gain, a profit, something of exchangeable value, proceeding from the property, severed from...coming in, being " derived" — that is, received or draion by the recipient (the taxpayer) for his separate use, benefit, and disposal — that Is Income...
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California Law Review, Volume 14

1926 - 552 pages
...207, 64 L. Ed. 521, 40 Sup. Ct. Rep. 189, 9 ALR 1570, Mr. Justice Pitney defines income as a gain " 'derived', that is, received or drawn by the recipient...taxpayer) for his separate use, benefit, and disposal". question alone was involved; it was conceded that if what was sought to be taxed was "income" it was...
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The Federal Reporter

1927 - 1126 pages
...not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value, proceeding from the property, severed from...received or drawn by the recipient (the taxpayer) for 20F.(2d)— 26 SO F.(2d) 885 The adding of in- his separate use, benefit, and disposal; thai is, income...
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The Federal Reporter

1927 - 1158 pages
...not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...however invested or employed, and coming in, being 'derived'—that is, received or drawn—by the recipient (the taxpayer) for his separate use, benefit,...
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The Central Law Journal, Volume 100

1927 - 224 pages
...not a growth or Increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the...capital however Invested or employed, and coming in, heing 'derived,' that is received or drawn by the recipient (the taxpayer) for his separate use, benefit...
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Reports of the U.S. Board of Tax Appeals, Volume 4

United States. Board of Tax Appeals - 1927 - 1522 pages
...a growth, or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the capital however invested or employed, and corn-ing in, being "derived," that is, received or draicn by the recipient (the taxpayer) for his ttfarate...
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The New Standard American Business Guide: A Complete Compendium of how to Do ...

Edward Thomas Roe - 1927 - 554 pages
...capital, from labor or from both combined. It is not a gain accruing to capital, but a gain or a profit proceeding from the property, severed from the capital, however invested or employed, and being received for the recipient's separate use, benefit and disposal. A stock dividend normally is...
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Reports of the U.S. Board of Tax Appeals, Volume 7

United States. Board of Tax Appeals - 1928 - 1582 pages
...Supreme Court in Eisner v. Mac&mber, 252 US 189 : * * * A gain, a profit, something of exchangeable value, proceeding from the property, severed from...being " derived ", — that Is, received or drawn ly the recipient (the taxpayer) for his separate use, benefit and disposal ; — that is income derived...
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