Case law

Appeal of Saner-Ragley Lumber Co.

3 B.T.A. 927 · United States Board of Tax Appeals · Feb 19, 1926

The Board has had occasion to pass directly upon the principle here involved in Appeal of Tel-Electric Co., 1 B. T. A. 434, and Appeal of North Wayne Tool Co., 2 B. T. … In the recent decision of the Supreme Court in United States v. Anderson, 269 U.

Appeal of Kerr

4 B.T.A. 829 · United States Board of Tax Appeals · Sep 15, 1926

United States v. Robbins, 269 U. S. 315 , and the decision of the Board in the Appeal of D. Cerruti, 4 B. T. A. 682. Judgment for the Commissioner.

Heilbroner v. Commissioner

34 B.T.A. 1200 · United States Board of Tax Appeals · Oct 22, 1936

A. 413, 425; aff'd., 58 Fed. (2d) 512, the Board said: How can it be said that these petitioners were carrying on a trade or business? … Reviewed by the Board. Judgment will be entered for the respondent. Leech dissents. Aet. 121.

Appeal of Seller

4 B.T.A. 811 · United States Board of Tax Appeals · Sep 15, 1926

OPINION., Littleton : The decision of the question involved in this proceeding is governed by the opinion of the court in United States v. Robbins, 269 U. S. 315 , and the decision of the Board in the Appeal of D.

Appeal of Young

4 B.T.A. 808 · United States Board of Tax Appeals · Sep 15, 1926

Littleton : The decision of the question involved in this proceeding is governed by the opinion of the court in United States v. Robbins, 269 U. S. 315 , and the decision of the Board in the Appeal of D. Cerruti, 4 B.

Appeal of Schneider

4 B.T.A. 817 · United States Board of Tax Appeals · Sep 15, 1926

Littleton : The decision of the question involved in this proceeding is governed by the opinion of the court in United States v. Robbins, 269 U. S. 315 , and the decision of the Board in the Appeal of D. Cerruti, 4 B.

Appeal of Lehn

4 B.T.A. 825 · United States Board of Tax Appeals · Sep 15, 1926

Littleton : The decision of the question involved in this proceeding is governed by the opinion of the court in United States v. Robbins, 269 U. S. 315 , and the decision of the Board in the Appeal of D. Cerruti, 4 B.

Appeal of Wagner

4 B.T.A. 822 · United States Board of Tax Appeals · Sep 15, 1926

Littleton : The decision of the question involved in this proceeding is governed by the opinion of the court in United States v. Robbins, 269 U. S. 315 , and the decision of the Board in the Appeal of D. Cerruti, 4 B.

Appeal of Haggarty

4 B.T.A. 806 · United States Board of Tax Appeals · Sep 15, 1926

Littleton : The decision of the question involved in this proceeding is governed by the opinion of the court in United States v. Robbins, 269 U. S. 315 , and the decision of the Board in the Appeal of D. Cerruti, 4 B.

Benjamin Electric Mfg. Co. v. Commissioner

6 B.T.A. 1204 · United States Board of Tax Appeals · Apr 30, 1927

In support of its position the petitioner cites the decision of the Board in the Appeal of Mahoning Coal Railroad Co., 4 B. T. A., 923. … A. 596; Adaskin-Tilley Furniture Co. v. Commissioner, 6 B. T. A. 316. In the Tunnel Railroad of St.

Alsberg v. Commissioner

42 B.T.A. 61 · United States Board of Tax Appeals · Jun 13, 1940

The facts have been stipulated and the stipulation is adopted by the Board as its findings of fact. The petitioner kept his books upon a cash basis. … Hart v. Commissioner, 54 Fed. (2d) 848; S. E. Thomason, supra; Eckert v. Burnet, 283 U. S. 140 . Cf. Oscar G. Joseph, 32 B. T. A. 1192.

Safe Deposit & Trust Co. v. Commissioner

35 B.T.A. 259 · United States Board of Tax Appeals · Jan 15, 1937

Cohan v. Commissioner , 39 Fed. (2d) 540, 543; Bryant v. Commissioner, 76 Fed. (2d) 103, 105; Clinton Cotton Mills, Inc. v. Commissioner , 78 Fed. (2d) 292, 295. … Beviewed by the Board. Judgment will be entered under Rule 50.

Appeal of Goss

4 B.T.A. 821 · United States Board of Tax Appeals · Sep 15, 1926

Littleton : The decision of the question involved in this proceeding is governed by the opinion of the court in United States v. Robbins, 269 U. S. 315 , and the decision of the Board in the Appeal of D. Cerruti, 4 B.

Art Metal Works v. Commissioner

9 B.T.A. 491 · United States Board of Tax Appeals · Dec 6, 1927

In addition to these cases, see also Erie Taxi v. Gnichtel, 17 Fed. (2d) 661, and United States v. … See Ogden v. Saunders, 12 Wheat. 349 ; Sturges v. Crowninshield, 4 Wheat. 122 . See also Campbell v. Holt, 115 U. S. 620 , as to the extent to which the law-making body may alter the statute of limitations.

Hooper v. Commissioner

41 B.T.A. 114 · United States Board of Tax Appeals · Jan 19, 1940

A history of the legislation is shown in Hassett v. Welch, 303 U. S. 303 . In Helvering v. Bullard, 303 U. … A similar holding was made by this Board in E. Pennington Pearson, Executor, 36 B. T. A. 5.

Heyman v. Commissioner

20 B.T.A. 174 · United States Board of Tax Appeals · Jun 30, 1930

BERMAN HEYMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Heyman v. Commissioner Docket No. 32275. … the date of final decision by said Board.

W. & K. Holding Corp. v. Commissioner

38 B.T.A. 830 · United States Board of Tax Appeals · Oct 12, 1938

. *846 Since the briefs were filed, tbe Board, the Court of Claims, and the Circuit Court for the Sixth Circuit have considered these provisions. The cases are: Glenn v. … Beviewed by the Board. Decision will be entered wider Bule 50.

Martin Hotel Co. v. Commissioner

24 B.T.A. 899 · United States Board of Tax Appeals · Nov 24, 1931

MARTIN HOTEL COMPANY AND AFFILIATED CORPORATIONS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Martin Hotel Co. v. Commissioner Docket No. 16275. … the date of final decision by said Board.

Minnesota Tea Co. v. Commissioner

28 B.T.A. 591 · United States Board of Tax Appeals · Jun 30, 1933

The extent of this literalism is indicated by Sarther Grocery Co. v. … The Fifth Circuit Court of Appeals, in Pinellas lee & Cold Storage Co. v.

Kessler v. Commissioner

31 B.T.A. 849 · United States Board of Tax Appeals · Dec 6, 1934

See Edson v. Lucas, 40 F. (2d) 398, 404 (C. C. A. 8), and cases there cited; Sizer et al. v. U. S., 65 Ct. Cl. 450 ; Lee v Lee, 55 App. D. C. 344, 5 F. (2d) 767. Cf. Basket v. Hassell, 107 U. S. 602, 614, 615 , 2 S. … Such was the case in Marshall v. Commissioner, supra. The respondent’s action is reversed. Reviewed by the Board. Judgment will he entered u/nder Rule 50.