Case law

Houston Baseball Ass'n v. Commissioner

24 B.T.A. 69 · United States Board of Tax Appeals · Sep 21, 1931

COMMISSIONER OF INTERNAL REVENUE, RESPONDENT., PETITIONER, v. Houston Baseball Ass'n v. Commissioner Docket Nos. 43985, 45430. … In case of dispute between the Player and the Club or any assignee hereof the same shall be referred to the National Board or the Commissioner as the case may be, as an umpire, and the Board's decision shall be accepted by

Mt. Vernon Car Mfg. Co. v. Commissioner

13 B.T.A. 810 · United States Board of Tax Appeals · Oct 5, 1928

It also relies upon the decision of this Board in W. C. Arthurs, 3 B. T. A. 374, where we held that the stock of the Lumber Mineral Co. was worth par on March 1, 1913. … The respondent points to this language of the statute, as interpreted by the Supreme Court of the United States in Willcuts v. Milton Dairy Co., 275 U.

Loose v. Commissioner

15 B.T.A. 169 · United States Board of Tax Appeals · Jan 31, 1929

In Nichols v. United States, 64 Ct. Cls. 241, the issue was substantially identical with that in the Frank case, the same item having been taxed as income of the estate and part of the corpus. … This issue is not presented in the instant case and the Board has heretofore indicated its concurrence with the conclusion of the Court of Claims that the same item may not be both income of an estate and also part of the

Marlin Grocery Co. v. Commissioner

15 B.T.A. 1080 · United States Board of Tax Appeals · Mar 26, 1929

MARLIN GROCERY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Marlin Grocery Co. v. Commissioner Docket No. 15384. … The Board held this improper and said in part: The point involved in this proceeding, namely, whether the inventory at December 31, 1920, was taken upon a proper basis, was substantially covered by the Board in .

Falcon Co. v. Commissioner

41 B.T.A. 1128 · United States Board of Tax Appeals · May 14, 1940

So did the Board in Conservative Gas Co., supra. … Reviewed by the Board. Decision will be entered under Rule 50. TotNer dissents.

Spreckels v. Commissioner

41 B.T.A. 1204 · United States Board of Tax Appeals · May 21, 1940

Neuberger v. Commissioner, 104 Fed. (2d) 649. Certiorari was not applied for by the Commissioner. We think the dicta in Helvering v. Winmill, 305 U. S. 79 , and in Helvering v. Union Pacific R. R. Co., 293 U. … A. 767, and, following Commissioner v. Rieck, supra, and Commissioner v.

First Nat'l Bank v. Commissioner

1 B.T.A. 9 · United States Board of Tax Appeals · Jan 1, 1924

First Nat'l Bank v. Commissioner Docket No. 19. … In order that the Board might decide this appeal upon its merits, the Commissioner admitted as true certain allegations of the petition and made oral statements from which the Board makes the following FINDINGS OF FACT. 1

Yamhill Elec. Co. v. Commissioner

20 B.T.A. 1232 · United States Board of Tax Appeals · Oct 10, 1930

In a recent Board case, Killian Co., 20 B. T. … American Rolling Mills Co. v. Commissioner, 41 Fed. (2d) 314, reversing, in part, 14 B. T. A. 529.

Fowler v. Commissioner

6 B.T.A. 250 · United States Board of Tax Appeals · Feb 19, 1927

In Bowen v. … This method has been approved by the Board in Appeal of M. Fowler, 1 B. T. A. 1212, and by the United States District Court for the Northern District of Texas in Fowler v. United States, 11 Fed. (2d) 895; 5 Am. Fed.

Bates-Bowman Corp. v. Commissioner

20 B.T.A. 460 · United States Board of Tax Appeals · Aug 4, 1930

BATES-BOWMAN CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Bates-Bowman Corp. v. Commissioner Docket No. 11357. … PHILLIPS: This is a proceeding under Rule 62(b) of the Board's rules of practice.

Pleasant Valley Ranch Co. v. Commissioner

2 B.T.A. 335 · United States Board of Tax Appeals · Jul 14, 1925

Pleasant Valley Ranch Co. v. Commissioner Docket No. 1315. United States Board of Tax Appeals 2 B.T.A. 335 ; 1925 BTA LEXIS 2433 ; July 14, 1925 , Decided Submitted May 26, 1925 . *2433 F. P. … The law imposes upon this Board the duty of making written findings of fact and it is impossible to find facts in the absence of evidence.

Winterbottom Book Cloth Co. v. Commissioner

43 B.T.A. 572 · United States Board of Tax Appeals · Feb 12, 1941

THE WINTERBOTTOM BOOK CLOTH COMPANY, LIMITED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Winterbottom Book Cloth Co. v. Commissioner Docket No. 97416. … The Board is not concerned with the difficulties that may beset the Commissioner in collecting a deficiency in tax after redetermination.

Hamilton Web Co. v. Commissioner

19 B.T.A. 199 · United States Board of Tax Appeals · Mar 4, 1930

(A RHODE ISLAND CORPORATION), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Hamilton Web Co. v. Commissioner Docket No. 15966. … the date of final decision by said Board.

Georgia Eng'g Co. v. Commissioner

21 B.T.A. 532 · United States Board of Tax Appeals · Dec 3, 1930

Spencer v. Low, supra; Maine v. Mills, 16 Fed. (2d) 974; Quinn v. Quinn Manufacturing Co., 167 N. W. 898 ; Northern Bank, etc., Co. v. Day, 145 Pac. 182 . … Reviewed by the Board. Judgment will be entered under Bule 50.

Brady v. Commissioner

22 B.T.A. 596 · United States Board of Tax Appeals · Mar 6, 1931

BRADY, ET AL., 1 PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Brady v. Commissioner Docket Nos. 40673-40683. … V.

Edward T. Bedford Trust v. Commissioner

42 B.T.A. 748 · United States Board of Tax Appeals · Sep 27, 1940

The Commissioner contends that the transfer was a gift, Burnet v. Guggenheim, 288 U. S. 280 ; the trustee “acquired by gift”, Helvering v. New York Trust Co., 292 U. … Reviewed by the Board. Dedsion will be entered u/nder Bule 50.

Forstmann v. Commissioner

6 B.T.A. 21 · United States Board of Tax Appeals · Feb 2, 1927

Forstmann v. Commissioner Docket No. 2521. … An appeal from the final determination of the deficiency was taken to this Board and the appeal was pending before the Board at the time of the enactment of the Revenue Act of 1926.

Udolpho Wolfe Co. v. Commissioner

15 B.T.A. 485 · United States Board of Tax Appeals · Feb 19, 1929

In Burrill v. Garst, 19 R. … Kornhauser v. United States, 276 U. S. 145 ; J. W. Forgeus, 6 B. T. A. 291; American Feature Film Co., 11 B. T. A. 1271; O'Day Investment Co., 13 B. T. A. 1230; Peter Frees, Jr., 12 B. T. A. 737; F.

Equitable Trust Co. v. Commissioner

1 B.T.A. 565 · United States Board of Tax Appeals · Feb 10, 1925

Equitable Trust Co. v. Commissioner Docket No. 1116. United States Board of Tax Appeals 1 B.T.A. 565 ; 1925 BTA LEXIS 2874 ; February 10, 1925 , decided Submitted February 5, 1925 . *2874 W. … At the hearing counsel presented a stipulation by which the parties agreed that the Board shall determine the deficiency in the sum of $60.27, upon which the Board hereby makes the following DECISION.

Cohn-Goodman Co. v. Commissioner

7 B.T.A. 475 · United States Board of Tax Appeals · Jun 23, 1927

ARtjndell : At the hearing of this case the respondent moved that the appeal be dismissed in so far as it relates to the years 1917 and 1918, as overassessments have been found for those years and the Board is therefore without … A. 1333; Lobsitz Hardware Co. v. Commissioner, 5 B. T. A. 295. The petitioner cites Eaton v. English & Mersick Co., 7 Fed. (2d) 54, and Davidson & Case Lumber Co. v.