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1954年,由美国联邦索赔法院作出最终判决的费城公园娱乐公司案,是美国税收历史上在有关财产转让中,如何确定没有公平市场价值财产(如特许权)成本的著名案例。背景资料 美国《国内收入法典》第61款规定,毛所得是指纳税人任何来源的所得(有特别规定的除外),并列举了15项应计入毛所得的所得,其中第3项就是处置财产的利得。由此需要关注两个问题:一是财产交易中是否实现了利得;二是如果实现了利得,实现了多少利得。
In 1954, the case of Philadelphia Park Entertainment, the final judgment of which was filed by the U.S. Federal Court of Claim, was a notable example of how the United States tax historically established the costs of unfair market value properties such as concessions in relation to the transfer of property. Background Information Section 61 of the Internal Revenue Code provides that gross income means income from any source of taxpayers (except where otherwise specified) and lists 15 items that are included in gross income, of which item 3 is disposal Profits from property. There are two issues that need attention: one is whether profits are realized in property transactions; and the other is how much is realized if the gains are realized.