Case law

Goldman v. Commissioner

24 B.T.A. 915 · United States Board of Tax Appeals · Nov 25, 1931

Their contention has been decided, adversely to them, in Phillips v. Commissioner, 283 U. S. 589 . … Within sixty days after June 13, 1927, the petitioners filed their petitions with this Board. .

Fulton v. Commissioner

11 B.T.A. 641 · United States Board of Tax Appeals · Apr 17, 1928

GUY FULTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Fulton v. Commissioner Docket No. 9362. … The following are the minutes of a special meeting of the board of directors held on September 10, 1920: A special meeting of the Board of Directors was held at the office of the company on September 10, 1920.

Ehrman v. Commissioner

41 B.T.A. 652 · United States Board of Tax Appeals · Mar 22, 1940

Commissioner, 77 Fed. (2d) 599; Richards v. Commissioner, 81 Fed. (2d) 369; Welch v. Solomon, 99 Fed. (2d) 41; and Commissioner v. Boeing, 106 Fed. (2d) 305. … Phipps v. Commissioner rests upon the conclusion that the transactions in the taxable year were not sufficient to constitute doing business, and Pope v.

Lindheim v. Commissioner

2 B.T.A. 913 · United States Board of Tax Appeals · Oct 19, 1925

Lindheim v. Commissioner Docket No. 2668. United States Board of Tax Appeals 2 B.T.A. 913 ; 1925 BTA LEXIS 2228 ; October 19, 1925 , Decided Submitted June 3, 1925 . *2228 David A. Buckley, C.P.A., for the taxpayer. B. … Aside from the concession that the taxpayer claimed to have contributed $4,002 in 1919 to some organization known as the Federation of American Zionists, no evidence other than the foregoing was placed before the Board.

Guaranty Trust Co. v. Commissioner

34 B.T.A. 384 · United States Board of Tax Appeals · Apr 21, 1936

Partnership Law of New York, secs. 60, 61, and 62. 2 As this Board held in Abe De Roy et al., Executors, 19 B. T. … The argument that the disputed income thus escapes income tax should be addressed to Congress, not to this Board. See Commissioner v. City Bank Farmers Trust Co., 296 U. S. 85 ; Sawtell v.

Brauer v. Commissioner

6 B.T.A. 579 · United States Board of Tax Appeals · Mar 22, 1927

It is immaterial as to what action the Commissioner took as regards the Schick-Johnson Co., for that determination by the Commissioner is not before the Board in this proceeding and that corporation and this petitioner are … In the case of Hayner v. United States, 62 Ct. Cls. 189, the court said in its opinion: It is admitted that the plaintiff received as salary .$13,195.79 and returned it as such for taxation.

Christy v. Commissioner

23 B.T.A. 300 · United States Board of Tax Appeals · May 18, 1931

CHARLES CHRISTY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Christy v. Commissioner Docket No. 26867. … A second allegation of error was abandoned at the hearing and only one question is submitted to the Board. The petitioner is a resident of Wichita, Kans.

First National Bank v. Commissioner

34 B.T.A. 631 · United States Board of Tax Appeals · May 27, 1936

Commissioner v. Blum, 75 Fed. (2d) 699, affirming 29 B. T. A. 580. … Alworth-Washburn Co. v. Helvering, 67 Fed. (2d) 694. Reviewed by the Board. Decision will be entered under Rule 50.

Hunt v. Commissioner

36 B.T.A. 268 · United States Board of Tax Appeals · Jun 30, 1937

State of Arkansas v. State of Tennessee, 246 U. S. 158, 176 ; Western Union Telegraph Co. v. Foster, 247 U. S. 105, 115 ; Bankers Pocahontas Coal Co. v. Burnet, 287 U. S. 308 . … Reviewed by the Board. Judgment will be entered for the respondent.

Boggs-Burnam & Co. v. Commissioner

26 B.T.A. 988 · United States Board of Tax Appeals · Sep 15, 1932

Gould v. Gould, 245 U. S. 151 ; Weeks v. Sibley, 269 Fed. 155 ; Jemison et al., Trustees, 3 B. T. A. 780. … In the Snead v.

Leonard v. Commissioner

36 B.T.A. 563 · United States Board of Tax Appeals · Sep 28, 1937

See also Helvering v. Grosvenor, 85 Fed. (2d) 2; Commissioner v. Hyde, 82 Fed. (2d) 174; Albert C. Whitaker, 38 B. T. A. 865. In Helvering v. … On the authority of the cases above cited, the order of the Board is reversed. Petitioner cites and relies on the case of Commissioner v. Tuttle, 89 Fed. (2d) 113, as controlling here.

Blumrosen v. Commissioner

19 B.T.A. 240 · United States Board of Tax Appeals · Mar 11, 1930

BLUMROSEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Blumrosen v. Commissioner Docket No. 36123. … This very question was before the Board and was decided in .

Coleman v. Commissioner

31 B.T.A. 319 · United States Board of Tax Appeals · Oct 12, 1934

In this connection the petitioner cites the decision of the Board in Union C. De Ford, 19 B. T. … Reviewed by the Board. Decision will be entered for the respondent. Black, Smith, and Akundell dissent.

Menominee Bay Shore Lumber Co. v. Commissioner

18 B.T.A. 499 · United States Board of Tax Appeals · Dec 12, 1929

Quinlan, and John V. … Reviewed by the Board. Judgment will he entered for the resfond&nt.

Selling v. Commissioner

22 B.T.A. 920 · United States Board of Tax Appeals · Mar 25, 1931

In Burk-Waggoner Oil Association v. Hopkins, 269 U. S. 110 ; 70 L. Ed. 67 , the Supreme Court said: “ the term ‘ partnership ’ as used in these sections obviously refers only to ordinary partnerships.” … Reviewed by the Board. Decision will Toe entered for the respondent.

Northwest Bancorporation v. Commissioner

33 B.T.A. 160 · United States Board of Tax Appeals · Oct 10, 1935

Brandon Corporation v. Commissioner, 71 Fed. (2d) 762. … Eeviewed by the Board. Decision will be entered for the resfondent.

Burge v. Commissioner

4 B.T.A. 732 · United States Board of Tax Appeals · Aug 4, 1926

Steam is not in point, and to support his views cites Marr v. United States, 268 U. S. 536 ; 45 Sup. Ct. 575; 5 Am. Fed. Tax Rep. 5393, and the decisions of this Board in Appeals of E. C. Huffman, 1 B. T. A. 52; J. K. … Thus, in Weiss v. Stearn , as in Eisner v.

Symons v. Commissioner

11 B.T.A. 886 · United States Board of Tax Appeals · Apr 30, 1928

HARRY SYMONS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Symons v. Commissioner Docket Nos. 8952, 17166. … In 1919 the board of directors resolved to abandon the corporate property and dissolve the company.

Hunter v. Commissioner

7 B.T.A. 1226 · United States Board of Tax Appeals · Sep 6, 1927

HUNTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Hunter v. Commissioner Docket No. 4123. … Under these circumstances, the Board can not do otherwise than approve the determination of the deficiency as found by the respondent. Judgment will be entered for the respondent.

Central Consumers Wine & Liquor Co. v. Commissioner

1 B.T.A. 1190 · United States Board of Tax Appeals · May 21, 1925

Land Co. v. Raymond, supra, and Sanger v. Upton, 91 U. S. 56 . … The above are the rates which this Board has heretofore allowed in the Appeal of Dwight & Lloyd Sintering Co., 1 B. T.