Case law

Howard Paper Co. v. Commissioner

43 B.T.A. 545 · United States Board of Tax Appeals · Feb 11, 1941

The respondent relies upon Helvering v. Jane Holding Corporation, 109 Fed. (2d) 933; certiorari denied, 310 U. S. 653 , and Beacon Auto Stores, Inc., 42 B. T. A. 703, which followed Helvering v. … That was the point which the Board emphasized as of controlling importance.

Hastings v. Commissioner

8 B.T.A. 670 · United States Board of Tax Appeals · Oct 10, 1927

A. 1240; Langstaff v. Lucas, 9 Fed. (2d) 691; aff'd. in 13 Fed. (2d) 1022. … In the opinion of the Board, however, the Commissioner was not in error in holding that the fair market value of the inventory was $132,160.35.

Jackson Iron & Steel Co. v. Glander

58 Ohio Law. Abs. 343 · United States Board of Tax Appeals · Feb 20, 1950

Secs. 5546-1 and 5546-25 GC were under consideration in Bailey v. … See The Cleveland-Cliffs Iron Co. v.

Whittemore v. Commissioner

35 B.T.A. 757 · United States Board of Tax Appeals · Mar 30, 1937

See Metcalf Eddy v. Mitchell, supra; Helvering v. Powers, 293 U. S. 214 . This question has come before this Board in a great many petitions. … Reviewed by the Board. Judgment will be entered for the respondent.

Muskegon Motor Specialties Co. v. Commissioner

45 B.T.A. 551 · United States Board of Tax Appeals · Nov 4, 1941

Nelson Co. v. Helvering, 296 U. S. 374 ; Helvering v. Minnesota Tea Co., 296 U. S. 378 ; Miller v. Commissioner (C. C. A., 6th Cir.), 84 Fed. (2d) 415. … Nelson Co. v. Helvering, supra. And that is all the provision requires.

Rovensky v. Commissioner

37 B.T.A. 702 · United States Board of Tax Appeals · Apr 15, 1938

The statute must be applied, if not strictly according to its language, Kaplan v. Commissioner, 66 Fed. (2d) 401; Warren H. Corning, 36 B. T. A. 301 (on review C. C. … Reviewed by the Board. Judgment toill be entered under Bule 50. Leech dissents. SEC. 166. REVOCABLE TRUSTS.

Penn Mut. Life Ins. Co. v. Commissioner

32 B.T.A. 876 · United States Board of Tax Appeals · Jun 28, 1935

Ilfeld Co. v. Hernandez, 292 U. S. 62, 66 . New Colonial Co. v. Helvering, 292 U. S. 435, 440 . The word “ reserve ” has many meanings. … McCoach v. Insurance Co. of N. Amer., 244 U. S. 585, 589 . United States v. Boston Insurance Co.. 269 U. S. 197, 202 . New York Ins. Co. v. Edwards, 271 U. S. 109, 119 . Duffy v. Mutual Benefit Co., 272 U.

McMurtrie v. Commissioner

8 B.T.A. 1301 · United States Board of Tax Appeals · Nov 7, 1927

Van Fossan: The facts in this case bring it squarely within the holding of the Board in Robert W. Bingham v. Commissioner, 8 B. T. A. 603, promulgated October 8, 1927. … Eeviewed by the Board. Judgment will be entered for the petitioner.

Monte Glove Co. v. Commissioner

44 B.T.A. 539 · United States Board of Tax Appeals · May 21, 1941

Richter & Co. v. Light (Conn.), 116 Atl. 600 ; Nutter v. Andrews (Mass.), 140 N. E. 744 . … Lincoln National Bank v. Burnet, 63 Fed. (2d) 131.

Dabney v. Commissioner

40 B.T.A. 276 · United States Board of Tax Appeals · Jul 25, 1939

This view of the New York law' was followed by the Circuit Court of Appeals for the Second Circuit in Olsen v. … Reviewed by the Board. Order will be entered dismissing the proceeding.

Consolidated Gas Co. v. Commissioner

24 B.T.A. 901 · United States Board of Tax Appeals · Nov 24, 1931

In Bowers v. … Burnet v. Sanford & Brooks Co., 282 U. S. 359, 364 . In Burnet v.

Bryan v. Commissioner

19 B.T.A. 111 · United States Board of Tax Appeals · Feb 28, 1930

show that *122 the Board does not have jurisdiction. … American Auto Trimming Co. v.

Ratliff v. Commissioner

36 B.T.A. 762 · United States Board of Tax Appeals · Oct 27, 1937

Without elaboration, it is sufficient to cite the following cases: In Darby-Lynde Co. v. … In Commissioner v.

Dohrmann v. Commissioner

19 B.T.A. 507 · United States Board of Tax Appeals · Apr 8, 1930

After quoting section 202 (b), supra, the court in O’Meara v. Commissioner, supra, in reversing the Board’s decision reported in 11 B. T. … In Tsivoglou v.

Martin Hotel Co. v. Commissioner

18 B.T.A. 826 · United States Board of Tax Appeals · Jan 15, 1930

United States Refining Co. v. Trinidad, 222 Fed. 1006 ; Hamilton v. Home Insurance Co., 137 U. S. 370 ; Jefferson Fire Ins. Co. v. Bierce, 183 Fed. 588 ; Mitchell v. Dougherty, 90 Fed. 639 . … This conclusion is not in conflict with the decision in the case of United States v. John Barth Co., 279 U. S. 370 .

Securities-Allied Corp. v. Commissioner

36 B.T.A. 168 · United States Board of Tax Appeals · Jun 18, 1937

This is not a matter of jurisdiction, for the Board clearly has the power of review, Blair v. Oesterlein Machine Co., 275 U. … A. 664; Schafer v. Helvering, 299 U. S. 171 , affirming 32 B. T. A. 289. Learned Hand, J., in Seeley v.

Ideal Reversible Hinge Co. v. Commissioner

7 B.T.A. 1066 · United States Board of Tax Appeals · Aug 9, 1927

The Board is not convinced that the fair-value inventory, as claimed by the petitioner, represents an inventory taken on the basis of cost or market, whichever is lower. … Sanford v.

Raymond v. Commissioner

34 B.T.A. 1171 · United States Board of Tax Appeals · Oct 20, 1936

Piper v. Willcuts (C. C. A., 8th Cir.), 64 Fed. (2d) 813; Echols v. Commissioner (C. C. A., 8th Cir.), 61 Fed. (2d) 191. In Crompton & Knowles Loom, Works v. White (C. C. … In Zellerbach Paper Co. v. Helvering, 293 U.

Steinbach Co. v. Commissioner

3 B.T.A. 348 · United States Board of Tax Appeals · Jan 16, 1926

The Supreme Court, in La Belle Iron Works v. United States, 256 U. … The opinion of the Board, supra, in respect of the taxpayer’s invested capital, controls the third issue in this appeal.

Farr v. Commissioner

33 B.T.A. 557 · United States Board of Tax Appeals · Nov 26, 1935

Y. 288 ; Appleman v. Fisher, 34 Md. 540 ; Lamprecht v. State, 84 Ohio, 32; 95 N. E. 656 ; Brown v. Carpenter, 168 N. Y. … Reviewed by the Board. Decision will he entered for the respondent. It is, however, possible to cover a short sale before the time for delivery. The Supreme Court, in Provost v. United States, 269 U.