§270 — Repealed. Pub. L. 91–172, title II, § 213(b), Dec. 30, 1969, 83 Stat. 572]
69 cases·4 followed·1 distinguished·2 criticized·62 cited—6% support
Statute Text — 26 U.S.C. §270
[§ 270. Repealed. Pub. L. 91–172, title II, § 213(b), Dec. 30, 1969, 83 Stat. 572] Section, act Aug. 16, 1954, ch. 736, 68A Stat. 81, related to the limitation on deductions allowable to certain individuals. See section 183 of this title. Statutory Notes and Related Subsidiaries Effective Date of RepealRepeal applicable to taxable years beginning after Dec. 31, 1969, see section 213(d) of Pub. L. 91–172, set out as an Effective Date note under section 183 of this title.
Treasury Regulations
- Treas. Reg. §Treas. Reg. §1.270-1 Limitation on deductions allowable to individuals in certain cases
- Treas. Reg. §Treas. Reg. §1.270-1(a) Recomputation of taxable income.
- Treas. Reg. §Treas. Reg. §1.270-1(b) Specially treated deductions.
- Treas. Reg. §Treas. Reg. §1.270-1(c) Applicability to taxable years otherwise subject to the Internal Revenue Code of 1939.
- Treas. Reg. §Treas. Reg. §1.270-1(d) Redetermination of tax.
- Treas. Reg. §Treas. Reg. §1.270-1(e) Assessment of tax.
- Treas. Reg. §Treas. Reg. §1.270-1(f) Effective date; cross reference.
- Treas. Reg. §Treas. Reg. §1.270-1(i) §1.270-1(i)
- Treas. Reg. §Treas. Reg. §1.270-1(v) §1.270-1(v)
69 Citing Cases
Therefore, we hold that petitioners are liable under section 6901 as transferees ofa transferee.
Therefore, we hold that petitioners are liable under section 6901 as transferees ofa transferee.
§ 1.270- 1(a)(4),33 which provides, in relevant part: Where several business activities emanate from a single commodity, such as oil or gas or a tract of land, it does not necessarily follow that such activities are one business for the purposes of section 270. However, in order to be treated separately, it must be established that such business activities are actually conducted separately and are not closely interrelated with each other. We reject petitioners’ arguments set forth above for seve
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. See Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchi
ate "to provide a medium for the 34(...continued) transfer the property ofthe business, or all or a large part ofthe stock, to trustees for themselves.'" Hanleyv. Kusper, 337 N.E.2d 1, 6 (Ill. 1975) (quoting G. Bogert, The Law ofTrusts and Trustees, sec. 270.40, at 347 (2d ed. 1964)). Sec. 301.7701-4(b), Proced. & Admin. Regs., merely restates the general principle that labels used by taxpayers are not conclusive. Sg Frank Lyon Co. v. United States, 435 U.S. 561, 583-584 (1978); see also Hutchin
270 (McKinney 2001). Fair consideration is given- - 27 - a. When in exchange for such property, or oËligation, as a fair equivalent therefor, and in good faith, propertyis conveyed or an antecedent debt is satisfied, or b. When such property, or obligation is received in good faith to secure a present advance or antecedent debt in a ount not
270.2a-7(b) and (c) (1997), we have also reclassified “Fidelity MI Muni Money Market” and “Short Term Income Fund- Govt.” (listed by Mr. Burns as a municipal bond fund and a U.S. Government bond fund, respectively) as money market funds, which is how they are classified in brokerage statements introduced into evidence. - 17 - November 21, 199