Case law

Chrysler Corp. v. Commissioner

42 B.T.A. 795 · United States Board of Tax Appeals · Sep 27, 1940

A. 258. *807 In the case of Gray & Co. v. … See Thurman v. Studebaker Corporation, 88 Fed. (2d) 984; Commissioner v. Texas Pipe Line Co., 87 Fed. (2d) 662.

Beck Engraving Co. v. Commissioner

8 B.T.A. 897 · United States Board of Tax Appeals · Oct 21, 1927

BECK ENGRAVING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Beck Engraving Co. v. Commissioner Docket No. 13037. … the date of final decision by said Board.

Eames v. Commissioner

4 B.T.A. 815 · United States Board of Tax Appeals · Sep 15, 1926

Eames v. Commissioner Docket No. 3235. United States Board of Tax Appeals 4 B.T.A. 815 ; 1926 BTA LEXIS 2177 ; September 15, 1926 , Decided *2177 A. G. Eames pro se. A. Calder Mackay, Esq., for the Commissioner. … LITTLETON: The decision of the question involved in this proceeding is governed by the opinion of the court in , and the decision of the Board in the . Judgment for the Commissioner.

Sterling & Welch Co. v. Commissioner

15 B.T.A. 925 · United States Board of Tax Appeals · Mar 18, 1929

A. 341, where a similar contention was made, the Board said: The Commissioner has determined that a 2 per cent rate for all of the years 1909 to 1920, is reasonable. … Doyle v. Mitchell Bros. Co., 247 U. S. 179 .

Seminole Hills Land Co. v. Commissioner

8 B.T.A. 882 · United States Board of Tax Appeals · Oct 20, 1927

Such opinion evidence is not entitled to much, if any, weight, for the Board must have before it sufficient facts to enable it to arrive at its own independent conclusions. *884 The record shows that approximately 60 days … In the case of Ruppert v. McArdle, 42 App. D. C. 392, the court said: Had there been no sale, the appraisements would have been a proper basis for judicial computation.

Chalmers Publishing Co. v. Commissioner

1 B.T.A. 629 · United States Board of Tax Appeals · Feb 27, 1925

Chalmers Publishing Co. v. Commissioner Docket No. 839. … This the Board can not countenance.

Pomeroy v. Commissioner

4 B.T.A. 807 · United States Board of Tax Appeals · Sep 15, 1926

Pomeroy v. Commissioner Docket No. 6234. United States Board of Tax Appeals 4 B.T.A. 807 ; 1926 BTA LEXIS 2164 ; September 15, 1926 , Decided *2164 Philip G. Sheehy, Esq., for the petitioner. A. … LITTLETON: The decision of the question involved in this proceeding is governed by the opinion of the court in , and the decision of the Board in the . Judgment for the Commissioner.

Black v. Commissioner

45 B.T.A. 204 · United States Board of Tax Appeals · Sep 26, 1941

Page v. Rhode Island Hospital Trust Co., 88 Fed. (2d) 192; cf. Helvering v. Price, 309 U. S. 409 , Burnet v. Huff, 288 U. S. 156 ; Eckert v. Burnet, 283 U. S. 140 ; Jenkins v. Bitgood, 101 Fed. (2d) 17. … Tams v. United States, 33 Fed. Supp. 764. Decision will he entered u/nder Rule SO. SEC. 23.

McDowell v. Commissioner

15 B.T.A. 947 · United States Board of Tax Appeals · Mar 18, 1929

MCDOWELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. MRS. S. L. MCDOWELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. McDowell v. Commissioner Docket Nos. 11271, 11272. … United States Board of Tax Appeals 15 B.T.A. 947 ; 1929 BTA LEXIS 2769 ; March 18, 1929 , Promulgated *2769 Harry C. Weeks, Esq., for the petitioners. Shelby Faulkner, Esq., for the respondent. GREEN *947 OPINION.

Faulkner v. Commissioner

4 B.T.A. 804 · United States Board of Tax Appeals · Sep 15, 1926

Faulkner v. Commissioner Docket No. 5883. United States Board of Tax Appeals 4 B.T.A. 804 ; 1926 BTA LEXIS 2159 ; September 15, 1926 , Decided *2159 Melvin D. Wilson, Esq., for the petitioner. A. … LITTLETON: The decision of the question involved in this proceeding is governed by the opinion of the court in , and the decision of the Board in the . Judgment for the Commissioner.

Bullock v. Commissioner

23 B.T.A. 710 · United States Board of Tax Appeals · Jun 15, 1931

The respondent in his brief “ further contends that if the Board should find that the reorganization resulted in a closed transaction in 1923, then the Board should also find that a gain resulted on the subsequent sale of … After citing United States v. Flannery, supra; McCaughn, v. Ludington, 268 U. S. 106 ; and Heiner v.

Pomeroy v. Commissioner

4 B.T.A. 826 · United States Board of Tax Appeals · Sep 15, 1926

Pomeroy v. Commissioner Docket No. 7415. United States Board of Tax Appeals 4 B.T.A. 826 ; 1926 BTA LEXIS 2196 ; September 15, 1926 , Decided *2196 Philip G. Sheehy, Esq., for the petitioner. A. … LITTLETON: The decision of the question involved in this proceeding is governed by the opinion of the court in , and the decision of the Board in the . Judgment for the Commissioner.

Brenneman v. Commissioner

10 B.T.A. 544 · United States Board of Tax Appeals · Feb 6, 1928

Appeal of Follmer, 37 Pa. 121 ; Hagerty v. Albright, 52 Pa. 274 . … Reviewed by the Board. Judgment will he entered on IS days' notice, under Bule SO. AruNdell dissents.

Mutual Oil Co. v. Commissioner

14 B.T.A. 538 · United States Board of Tax Appeals · Dec 4, 1928

OF ARIZONA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Mutual Oil Co. v. Commissioner Docket No. 11795. … the date of final decision by said Board.

Gurnee v. Commissioner

13 B.T.A. 262 · United States Board of Tax Appeals · Aug 17, 1928

This question at first glance would seem to be governed by the decision in Baltzell v. Mitchell, 3 Fed. (2d) 428, and the decisions of the Board which are collated in Arthur H. Fleming, 6 B. T. A. 900. … Merchants Loan & Trust Co. v. Smietanka, 255 U. S. 509 .

T. G. Northwall Co. v. Commissioner

13 B.T.A. 881 · United States Board of Tax Appeals · Oct 10, 1928

Ayer v. Blair, 26 Fed. (2d) 547. The record is not clear as to petitioner’s position with regard to the second issue. In the petition the amount is claimed as a deduction for actual depreciation sustained. … Reviewed by the Board. Decision will he entered for the resfondent.

Simmons Co. v. Commissioner

8 B.T.A. 631 · United States Board of Tax Appeals · Oct 8, 1927

A. 705; United States Corporation Bureau v. Commissioner, 6 B. T. … See, however, La Belle Iron Works v.

City & Suburban Mortg. Co. v. Commissioner

26 B.T.A. 179 · United States Board of Tax Appeals · May 25, 1932

CITY AND SUBURBAN MORTGAGE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. City & Suburban Mortg. Co. v. Commissioner Docket No. 45658. … At a regular meeting of the board of directors on September 14, 1927, it was voted that the corporation should be liquidated.

Bruce v. Commissioner

30 B.T.A. 80 · United States Board of Tax Appeals · Mar 13, 1934

ELIZABETH BRUCE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Bruce v. Commissioner Docket No. 67862. … Bruce & Co. *1383 The board of directors of E. E.

Estate of Fish v. Commissioner

42 B.T.A. 260 · United States Board of Tax Appeals · Jun 28, 1940

Corning v. Commissioner, 104 Fed. (2d) 329; John Edward Rovensky, 37 B. T. A. 702. … Reviewed by the Board. 1 See p. 1448 for dissenting opinion.