Case law

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

25 B.T.A. 631 · United States Board of Tax Appeals · Feb 25, 1932

V. Whitcomb et al., 4 B. T. A. 80; Whitcomb v. Blair, 25 Fed. (2d) 528; Codman v. Miles, 28 Fed. (2d) 823; Irwin v. Gavit, 268 U. S. 161 . … Reviewed by the Board. Decision will be entered u/nder Bule 50.

Brown v. Commissioner

22 B.T.A. 678 · United States Board of Tax Appeals · Mar 11, 1931

These duties include many which can not be definitely related to any particular line of business, such as the appointment and removal of local agents, representation of the firm’s principals on the Pacific Board of Fire Underwriters … See also, Consolidated Tea Co. v. Bowers, 19 Fed. (2d) 382; and Malleable Iron Range Co. v. United States, 62 Ct. Cls. 425. Judgment will be entered under Rule 50.

Brown v. Commissioner

29 B.T.A. 1183 · United States Board of Tax Appeals · Feb 23, 1934

Kengel v. United States, 57 Fed. (2d) 929. … Reviewed by the Board. Decision will be entered for the respondent. Sbc. 303.

Brown v. Commissioner

12 B.T.A. 841 · United States Board of Tax Appeals · Jun 27, 1928

Atlantic Casket Co. v. Rose, 22 Fed. (2d) 800. Judgment wild be entered for the respondent.

Brown v. Commissioner

27 B.T.A. 176 · United States Board of Tax Appeals · Nov 29, 1932

Reviewed by the Board. Decision will Toe entered for the respondent. Lansdon dissents.

Brown v. Comm'r

25 B.T.A. 814 · United States Board of Tax Appeals · Mar 8, 1932

Brown. As we consider this case we become convinced that in agreeing to transfer to petitioner his patent applications, Brown was motivated not by the money advanced by Mrs. … petitioner may not have a deduction on account of depreciation because she was not the owner of the patents during the years here involved, but was only the beneficiary of a trust, respondent cites the cases of Baltzell v.

Brown v. Commissioner

26 B.T.A. 781 · United States Board of Tax Appeals · Aug 9, 1932

Petitioner also relies upon the decision in Burnet v. Logan, 283 U. S. 404 . … See also Commissioner v. Moore, 48 Fed. (2d) 526 (certiorari denied) ; Commissioner v. Garber, 50 Fed. (2d) 588.

Brown v. Commissioner

22 B.T.A. 1117 · United States Board of Tax Appeals · Apr 8, 1931

In Stange v. United States, 282 U. … In Aiken v.

Brown v. Commissioner

36 B.T.A. 178 · United States Board of Tax Appeals · Jun 18, 1937

Brown, Inc.,- and therefore petitioner is not entitled to have the gain resulting from such transactions taxed at capital gain rates. … Reviewed by the Board. Judgment will be entered for the respondent..

Brown v. Commissioner

40 B.T.A. 934 · United States Board of Tax Appeals · Nov 24, 1939

The Board and the courts have so held in numerous cases. … A. 251, tlie Board said; The cited cases [Helvering v. Helmholz, 296 U. S. 93 , and White v. Poor, 296 U.

Brown v. Commissioner

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

Brown v. Commissioner

4 B.T.A. 74 · United States Board of Tax Appeals · Apr 23, 1926

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

4 B.T.A. 56 · United States Board of Tax Appeals · Apr 22, 1926

Arundell: The profit realized on the transaction whereby petitioner transferred his undivided interest in the copartnership to the Brown-Crummer Co., a corporation of the same. name, is taxable under the provisions of section … Upon liquidation of the partnership of Brown-Crummer Co. on May 15, 1919, petitioner’s share of the partnership profits, which amounted to $6,111.43, was taxable to him under the provisions of section 218 (a) of the Revenue

Brown v. Commissioner

5 B.T.A. 209 · United States Board of Tax Appeals · Oct 27, 1926

Brown, is entitled to a deduction in 1918 or 1919 with respect to advances made to the Ajax Co., and whether he is entitled to a loss with respect to his investment in the stock of that company. … There is no evidence that Brown exercised bad judgment in his control of the corporation in acquiring the properties which the corporation operated.

Brown v. Commissioner

1 B.T.A. 502 · United States Board of Tax Appeals · Jan 31, 1925

. *504 While the Commissioner in adjusting the tax liability of the taxpayer treated the stock and bonds in excess of the amount thereof which was sold during 1917 as worthless, the Board finds no evidence of the worthlessness … It is the opinion of the Board that the entire gain arising from the sale of the two farms in question was received in 1917.

Brown v. Commissioner

27 B.T.A. 176 · United States Board of Tax Appeals · Nov 29, 1932

Reviewed by the Board. Decision will Toe entered for the respondent. Lansdon dissents.

Brown v. Commissioner

9 B.T.A. 753 · United States Board of Tax Appeals · Dec 21, 1927

Brown v. Commissioner

47 B.T.A. 139 · United States Board of Tax Appeals · Jun 16, 1942

The Second Circuit Court of Appeals in two cases, Seaside Improvement Co. v. Commissioner, supra, and Commissioner v. Appleby Estate, supra, and the Board in Henry A. … Burnet v. Houston, 283 U. S. 223 . Fourth Issue.