Case law

Brown & Brown, Inc. v. Commissioner

10 B.T.A. 106 · United States Board of Tax Appeals · Jan 23, 1928

Aeundell: From the detailed facts set forth in the findings we have no difficulty in reaching the conclusion that substantially all of the stock of petitioner and the Brown McPhee Lumber Co. was, during the year 1921, owned … Brown and Horatio J. Brown for the year 1919, only $6,000 was paid to each and no additional amount was accrued on the books of petitioner nor claimed by it as a deduction in its income-tax return for the year 1919.

Brown & Brown, Inc. v. Commissioner

10 B.T.A. 106 · United States Board of Tax Appeals · Jan 23, 1928

Aeundell: From the detailed facts set forth in the findings we have no difficulty in reaching the conclusion that substantially all of the stock of petitioner and the Brown McPhee Lumber Co. was, during the year 1921, owned … Brown and Horatio J. Brown for the year 1919, only $6,000 was paid to each and no additional amount was accrued on the books of petitioner nor claimed by it as a deduction in its income-tax return for the year 1919.

Brown v. Commissioner

13 B.T.A. 832 · United States Board of Tax Appeals · Oct 9, 1928

This Board has recognized that a person may be regularly *834 engaged in more than one trade or business at the same time. Louis M. Goldberg, 9 B. T. A. 1355. … Reviewed by the Board. Judgment will be entered under Buie 50.

Brown v. Commissioner

26 B.T.A. 901 · United States Board of Tax Appeals · Aug 29, 1932

Brown owned 51% and Harry A. Brown owned 49% of the capital stock of Squire Dingee Company. 7. … S. 418 ; Eisner v. Macomber, 252 U. S. 189 ; La Belle Iron Works v. United States, 256 U. S. 377 ; see also Graves v. Graves, 120 Atl. 420 ; Kaufman v. Charlottesville Co., 23 S. E. 1003 ; United States v.

Brown v. Commissioner

18 B.T.A. 859 · United States Board of Tax Appeals · Jan 20, 1930

Similar claims of the Government have been held to be unfounded, McFarland v. United States, 15 Fed. (2d) 823; United States v. Avery, 30 Fed. (2d) 728; United States v. … McFarland v. United States, supra.

Brown v. Commissioner

10 B.T.A. 1122 · United States Board of Tax Appeals · Mar 1, 1928

In Norton v. Shelby County, 118 U. … Reviewed by the Board. Judgment will be entered for the respondent.

Brown v. Commissioner

10 B.T.A. 1036 · United States Board of Tax Appeals · Feb 28, 1928

The next question is whether the amount paid petitioner, James Crosby Brown, by one Bache to induce Brown to purchase certain stock of the Kali Inla Coal Co. is a reduction of the cost of the stock to Brown or whether it … Reviewed by the Board. Judgment will he entered on It days’ notice, under Rule 50. Steijnhagen dissents in part.

Brown v. Commissioner

9 B.T.A. 521 · United States Board of Tax Appeals · Dec 9, 1927

Reviewed by the Board. Judgment will be entered for the petitioners.

Brown v. Commissioner

42 B.T.A. 693 · United States Board of Tax Appeals · Sep 10, 1940

Brown. and to change the trustee. She did not exercise any of her reserved rights until after 1935, when she changed the trustee and provided that the income in excess of $35 per month should be paid to Paul G. Brown. … Commissioner v. Richter, 114 Fed. (2d) 452; Helvering v. Wood, 309 U. S. 344 ; Rhodes v. Commissioner, 111 Fed. (2d) 53), and the decision should not go against him until he has had that opportunity.

Brown v. Commissioner

46 B.T.A. 782 · United States Board of Tax Appeals · Mar 27, 1942

No such issue was raised by the pleadings and the Board might have disposed of the question on that ground. … Commissioner v. Brown, 122 Fed. (2d) 800.

Brown v. Commissioner

22 B.T.A. 581 · United States Board of Tax Appeals · Mar 5, 1931

S. 429 ; Metcalf & Eddy v. Mitchell, supra. In United States v. … Eeviewed by the Board. Decision will he entered for the petitioner.

Brown v. Commissioner

35 B.T.A. 111 · United States Board of Tax Appeals · Dec 3, 1936

McCulloch v. Maryland, 4 Wheat. 316 ; Collector v. Day, 11 Wall. 113 ; Ambrosini v. United States, 187 U. S. 1 ; Metcalf & Eddy v. Mitchell, 269 U. S. 514 ; McCallen Co. v. Massachusetts, 279 U. … Reviewed by the Board. Judgment %oill he entered for the respondent.

Brown v. Commissioner

20 B.T.A. 47 · United States Board of Tax Appeals · Jun 13, 1930

See Vidal v. Girard, 43 U. S. 126, 196 , and footnote to Wheeler v. Smith, 50 U. S. 55 ; In re Dulles’ Estate, 218 Pa. 162 ; 67 Atl. 49 . … Bekins v. Smith, 37 Cal. App. 222 ; 174 Pac. 96 .

Brown v. Commissioner

40 B.T.A. 565 · United States Board of Tax Appeals · Sep 28, 1939

The partnership of Burroughs & Brown, though dissolved by the death of Burroughs in June of 1929, had an income of $41,800 in 1933. … Eeviewed by the Board. Judgment will be entered for the respondent.

Brown v. Commissioner

13 B.T.A. 981 · United States Board of Tax Appeals · Oct 12, 1928

Milliken: The questions presented in these five proceedings are, (1) Were the petitioners’ wives, Bessie Brown and Frances Israel, partners in the firm of Brown-Israel Outfitting Co., and (2) if so, should their income therefrom … We do not deem the cases of United States v. Robbins, 269 U. S. 315 ; Blair v. Roth, 22 Fed. (2d) 932; and H. A. Belcher, 11 B. T. A. 1294, applicable to the facts of the cases under consideration.

Brown v. Commissioner

12 B.T.A. 401 · United States Board of Tax Appeals · Jun 5, 1928

The Board has heretofore decided the second claim adversely to the petitioner. See Charles E. Nauss, 4 B. T. A. 980; E. O. Walgren, 4 B. T. A. 1066; and many others of like import.

Brown v. Commissioner

24 B.T.A. 30 · United States Board of Tax Appeals · Sep 16, 1931

Lena Brown and Mrs. … The same principle was applied in Waller v. Commissioner, 40 Fed. (2d) 892, and Herold v. Commissioner, 42 Fed. (2d) 942, in which a lease interest was transferred instead of a royalty. Our decision in United States v.

Brown v. Commissioner

6 B.T.A. 895 · United States Board of Tax Appeals · Apr 19, 1927

Brown v. Commissioner

41 B.T.A. 582 · United States Board of Tax Appeals · Mar 19, 1940

In Stelling v. Stelling, 330 Ill. 155 ; 161 N. … The opinion of the Board, promulgated at 40 B. T. A. 934, is modified accordingly. Reviewed by the Board. Decision will be entered under Rule 60.

Brown v. Commissioner

19 B.T.A. 568 · United States Board of Tax Appeals · Apr 15, 1930

Lucas v. Howard, 280 U. S. 14A; Metcalf & Eddy v. Mitchell, 269 U. S. 514 ; Blair v. Byers, 35 Fed. (2d) 326; Kreipke v. Commissioner, 32 Fed. (2d) 594; Clarence H. Johnston, 14 B. T. A. 605; R. Clipston Sturgis, 10 B. … Beviewed by the Board. Decision will be entered for the respondent.