Case law

R. D. Fleming Co. v. Commissioner

1 B.T.A. 997 · United States Board of Tax Appeals · Apr 13, 1925

Fleming Co. v. Commissioner Docket No. 736. United States Board of Tax Appeals 1 B.T.A. 997 ; 1925 BTA LEXIS 2717 ; April 13, 1925 , decided Submitted March 31, 1925 . *2717 Newell W. Ellison, Esq., for the taxpayer. … From the peladings and from the statement made by counsel for the Commissioner at the hearing the Board makes the following FINDINGS OF FACT.

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.

First Nat'l Bank v. Commissioner

36 B.T.A. 491 · United States Board of Tax Appeals · Aug 31, 1937

Smith: The identical question raised in the first issue has been decided by the Board recently in Dwight Whiting et al., Trustees, 35 B. T. … In Smith v.

Davis v. Commissioner

6 B.T.A. 1267 · United States Board of Tax Appeals · May 10, 1927

DAVIS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Davis v. Commissioner Docket No. 9436. … The Commissioner did not wholly acquiresce in the Board's decision and now claims an additional tax for 1922 and prior years in the amount of $12,390.43.

Will County Title Co. v. Commissioner

38 B.T.A. 1396 · United States Board of Tax Appeals · Dec 15, 1938

WILL COUNTY TITLE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Will County Title Co. v. Commissioner Docket No. 91448. … The excess profits tax is imposed by section 702(a), which is a part of title V of the Revenue Act of 1934.

Churchill v. Commissioner

1 B.T.A. 168 · United States Board of Tax Appeals · Dec 11, 1924

Churchill v. Commissioner Docket No. 166. … The Board, therefore, must find the value to have been equal to their face value.

Illinois Terminal Co. v. Commissioner

5 B.T.A. 15 · United States Board of Tax Appeals · Oct 4, 1926

Co. v. Lee, 260 U. S. 16 ; Missouri Pacific R. R. Co. v. Ault, 256 U. S. 554 . … Having under consideration a somewhat analogous situation, the Court of Claims, in Johnson v. United States (1866), 2 Ct.

Quaker Maid, Inc. v. Commissioner

10 B.T.A. 301 · United States Board of Tax Appeals · Jan 27, 1928

QUAKER MAID, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Quaker Maid, Inc. v. Commissioner Docket No. 11421. … United States Board of Tax Appeals 10 B.T.A. 301 ; 1928 BTA LEXIS 4140 ; January 27, 1928 , Promulgated *4140 Attilla Cox, Esq., and E. J. Wells, Esq., for the petitioner. M. N. Fisher, Esq., for the respondent.

Effron v. Commissioner

25 B.T.A. 853 · United States Board of Tax Appeals · Mar 14, 1932

Weiss v. Wiener, 279 U. S. 333 . In Stephenson v. … In Rawson v. Brown, 104 Ohio St. 537 ; 136 N. E. 209 , the court decided that a perpetual leasehold with privilege of purchase is subject to partition. The option clause in the lease agreement in the Rawson v.

Richardson v. Commissioner

4 B.T.A. 816 · United States Board of Tax Appeals · Sep 15, 1926

Richardson v. Commissioner Docket No. 6236. United States Board of Tax Appeals 4 B.T.A. 816 ; 1926 BTA LEXIS 2180 ; September 15, 1926 , Decided *2180 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.

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 .

Appeal of Fort Wayne Engineering & Manufacturing Co.

2 B.T.A. 1223 · United States Board of Tax Appeals · Nov 6, 1925

The Board has had occasion to consider questions similar to the present one in Appeal of Warren-Lamb Lumber Co., 1 B. T. A. 786, and in Appeal of Middleton Compress & Warehouse Co., 1 B. T. … Doyle v. Mitchell Brothers Co., 247 U. S. 179 ; Douglas v. Ed wards, 298 Fed. 229, 234 ; Appeal of Even Realty Co., 1 B. T. A. 355.

Flynn v. Commissioner

21 B.T.A. 1329 · United States Board of Tax Appeals · Jan 22, 1931

This Board has no jurisdiction as to the deficiencies determined for the years 1913 and 1914. David B. Mills, 1 B. T. A. 199; Lancaster Lens Co., 10 B. T. A. 1153. … United States v. Railroad Co., 11 Wall. 322. The petitioner is not like the Alien Property Custodian, because the latter did not hold property in trust.

Young v. Commissioner

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

Young v. Commissioner Docket No. 6445. United States Board of Tax Appeals 4 B.T.A. 808 ; 1926 BTA LEXIS 2166 ; September 15, 1926 , Decided *2166 Garnett Young 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.

Dandridge v. Commissioner

11 B.T.A. 421 · United States Board of Tax Appeals · Apr 6, 1928

Langstaff v. Lucas, 13 Fed. (2d) 1022; 5 Am. Fed. Tax Rep. 6125; Hellmich v. Hellman, 276 U. S. 233 ; John K. Greenwood, 1 B. T. A. 291; E. T. Renfro et al., 8 B. T. A. 1295. Reviewed by the Board.

Haystone Sec. Corp. v. Commissioner

19 B.T.A. 954 · United States Board of Tax Appeals · May 14, 1930

HAYSTONE SECURITIES CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Haystone Sec. Corp. v. Commissioner Docket No. 23160. … United States Board of Tax Appeals 19 B.T.A. 954 ; 1930 BTA LEXIS 2293 ; May 14, 1930 , Promulgated *2293 A portion of a dividend declared and distributed in 1923 which represented earnings accumulated since February 28,

Tyler & Hippach, Inc. v. Commissioner

6 B.T.A. 636 · United States Board of Tax Appeals · Mar 28, 1927

TYLER & HIPPACH, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Tyler & Hippach, Inc. v. Commissioner Docket No. 995. … United States Board of Tax Appeals 6 B.T.A. 636 ; 1927 BTA LEXIS 3451 ; March 28, 1927 , Promulgated *3451 1.

Wilson Syndicate Trust v. Commissioner

14 B.T.A. 508 · United States Board of Tax Appeals · Nov 30, 1928

But arriving at that conclusion, does not solve the problem presented to the Board. In the case of Burk-Waggoner Oil Association v. Hopkins, 269 U. … See also Hecht v. Malley, 265 U. S. 144 .

McCauley v. Commissioner

17 B.T.A. 886 · United States Board of Tax Appeals · Oct 11, 1929

In Reynolds v. … This case was followed by the Board in N. H. Boynton, 11 B. T.

Purdy & Henderson Co. v. Commissioner

4 B.T.A. 70 · United States Board of Tax Appeals · Apr 23, 1926

Purdy & Henderson Co. v. Commissioner Docket No. 5198. … United States Board of Tax Appeals 4 B.T.A. 70 ; 1926 BTA LEXIS 2373 ; April 23, 1926 , Decided Submitted November 18, 1925 . *2373 The income and profits tax paid by the taxpayer corporation to the government of Porto Rico