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accounting adjusted basis allowed alternative minimum tax assets bonds capital gain cash Circuit claim client Commissioner compensation computing Congress contract contributions Corp corporation cost Court of Appeals debt decision depreciation determined disallowed dividends earnings employee exchange excluded exemption expenditures fact fair market value filing gain or loss gift gift tax gross income Helvering income tax incurred indebtedness interest Internal Revenue Internal Revenue Code investment issue itemized deductions L.Ed lawyers lease liability loan ment mortgage obligation ordinary income paid payments percent petitioner Problem profit progressive tax provides purchase purposes qualified receipt received recognized regulations rental result Rev.Rul Roth IRA rule S.Ct salary Section securities sells shareholders sold spouse statute Supreme Court tax benefit Tax Court tax-exempt taxable income taxation taxpayer tion trade or business traditional IRA transaction transfer Treas.Reg U.S.Tax United UNITED STATES CODE X Corp