Case law

Davidson v. Commissioner

3 B.T.A. 47 · United States Board of Tax Appeals · Nov 14, 1925

Davidson v. Commissioner Docket No. 2593. … The remaining value of the entire property on March 1, 1913, was the value of the oil content of the wells on that date, which the Board finds to be $32,460.

Menger v. Commissioner

17 B.T.A. 998 · United States Board of Tax Appeals · Oct 17, 1929

MENGER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. H. H. BRICKELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Menger v. Commissioner Docket Nos. 21589, 21590. … No appeal was filed by the taxpayer with the United States Board of Tax Appeals.

G. U. R. Co. v. Commissioner

41 B.T.A. 223 · United States Board of Tax Appeals · Jan 30, 1940

The Board said (pp. 1156, 1159): * * * The increment in the value of the property was converted into a realized profit within the group. … A purpose to evade taxes might evidence the absence of legitimate purpose, Gregory v. Helvering, 293 U. S. 465 ; but evasion of taxes is not the sole justification for resort to section 45.

Glenwood Hotel Co. v. Commissioner

5 B.T.A. 985 · United States Board of Tax Appeals · Dec 31, 1926

GLENWOOD HOTEL CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Glenwood Hotel Co. v. Commissioner Docket No. 2919. … At a meeting of the board of directors of the petitioner held May 16, 1921, the following resolution was adopted: Whereas, the corporation is the owner of certain securities, which, in the opinion of the board of directors

Cheney v. Commissioner

1 B.T.A. 1003 · United States Board of Tax Appeals · Apr 13, 1925

Cheney v. Commissioner Docket No. 912. … From the petition and answer and the admissions of the Commissioner made at the hearing the Board makes the following FINDINGS OF FACT. 1. The taxpayer is an individual residing at Allgood, Ala.

Edison Sec. Corp. v. Commissioner

34 B.T.A. 1188 · United States Board of Tax Appeals · Oct 21, 1936

EDISON SECURITIES CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Edison Sec. Corp. v. Commissioner Docket No. 52662. … In accordance with this stipulation and with the holding of the Board upon the matter in issue, Judgment will be entered under Rule 50.

American Packing & Provision Co. v. Commissioner

36 B.T.A. 340 · United States Board of Tax Appeals · Jul 16, 1937

In United States v. … Garland Coal & Mining Co. v. Helvering, 75 Fed. (2d) 663, is not in point, for there the obligor acquired them in the earlier year. Reviewed by the Board. Decision will be entered for the respondent.

Producers Livestock Marketing Asso. v. Commissioner

45 B.T.A. 325 · United States Board of Tax Appeals · Oct 10, 1941

PRODUCERS LIVESTOCK MARKETING ASSOCIATION OF SALT LAKE CITY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Producers Livestock Marketing Asso. v. Commissioner Docket No. 99706. … Reviewed by the Board. Decision will be entered for the respondent. Footnotes 1.

Hagemeister Food Products Co. v. Commissioner

2 B.T.A. 21 · United States Board of Tax Appeals · Jun 10, 1925

Hagemeister Food Products Co. v. Commissioner Docket No. 650. United States Board of Tax Appeals 2 B.T.A. 21 ; 1925 BTA LEXIS 2577 ; June 10, 1925 , Decided Submitted May 6, 1925 . *2577 T. P. … These fixtures consisted of bar fixtures, drain boards, refrigerators, mirrors, partitions, etc.

Michigan Steel Corp. v. Commissioner

38 B.T.A. 435 · United States Board of Tax Appeals · Aug 30, 1938

MICHIGAN STEEL CORPORATION OF NEW JERSEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Michigan Steel Corp. v. Commissioner Docket No. 82404. … Following Groman v. Commissioner, 302 U.S. 82 ; Helvering v. Bashford, 302 U.S. 454 ; and A. W. Mellon, 36 B.T.A. 977 . 2.

Madera Yosemite Big Tree Auto Co. v. Commissioner

2 B.T.A. 346 · United States Board of Tax Appeals · Jul 14, 1925

Madera Yosemite Big Tree Auto Co. v. Commissioner Docket No. 1974. … From the pleadings and depositions introduced at the hearing the Board makes the following FINDINGS OF FACT. The taxpayer is a California corporation with principal office in Wawona.

Shore v. Commissioner

26 B.T.A. 389 · United States Board of Tax Appeals · Jun 13, 1932

The only question submitted to the Board is whether the language in the lease contracts quoted above conveys a present interest in income-producing property or is a mere direction to govern the lessee in distributing the … A. 350; Rosenwald v. Commissioner, 33 Fed. (2d) 423; Hazel T. Power, 23 B. T. A. 428. Decision will be entered under Rule 50.

Berthold v. Commissioner

12 B.T.A. 1306 · United States Board of Tax Appeals · Jul 12, 1928

ELIZABETH BERTHOLD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. LOUISE K. SOLFISBURG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF JOHN F. THORWARTH, PETITIONER, v. … JOHN KNELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Berthold v. Commissioner Docket Nos. 7248-7250, 7638, 7420.

France Co. v. Commissioner

29 B.T.A. 661 · United States Board of Tax Appeals · Jan 3, 1934

THE FRANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. France Co. v. Commissioner Docket No. 64869. … On January 18, 1929, petitioner's board of directors authorized its officers to enter into said agreement by virtue of a shareholders' resolution passed on the same date.

Youngstown Bread Co. v. Commissioner

2 B.T.A. 402 · United States Board of Tax Appeals · Sep 7, 1925

Youngstown Bread Co. v. Commissioner Docket No. 1333. United States Board of Tax Appeals 2 B.T.A. 402 ; 1925 BTA LEXIS 2391 ; September 7, 1925 , Decided Submitted May 23, 1925 . *2391 Adrian C. … On reference to the Board, ARUNDELL took no part in the consideration.

Hawks v. Nursery Co. v. Commissioner

1 B.T.A. 1207 · United States Board of Tax Appeals · May 23, 1925

Hawks v. Nursery Co. v Commissioner Docket No. 1469. United States Board of Tax Appeals 1 B.T.A. 1207 ; 1925 BTA LEXIS 2613 ; May 23, 1925 , decided Submitted May 6, 1925 . *2613 Charles H. Hawks, Jr., for the taxpayer. … The sole issue before the Board is the March 1, 1913, value of the land described in the findings. FINDINGS OF FACT. 1.

California Sanitary Co. v. Commissioner

32 B.T.A. 122 · United States Board of Tax Appeals · Feb 20, 1935

CALIFORNIA SANITARY COMPANY, LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. California Sanitary Co. v. Commissioner Docket No. 68655. … Other provisions of the code relate to the procedure as to the assessment, proceedings before boards of equalization, levying of the tax, and methods of collection.

Bates v. Commissioner

4 B.T.A. 1079 · United States Board of Tax Appeals · Sep 27, 1926

BATES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Bates v. Commissioner Docket No. 10179. … United States Board of Tax Appeals 4 B.T.A. 1079 ; 1926 BTA LEXIS 2071 ; September 27, 1926 , Decided *2071 Coupons payable January 1, 1923, and deposited in a bank for collection on December 23, 1922, constitute income of

Hopkins v. Commissioner

27 B.T.A. 1331 · United States Board of Tax Appeals · Apr 28, 1933

WALTER HOPKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Hopkins v. Commissioner Docket No. 50984. … Reviewed by the Board. Judgment will be entered for the respondent. Footnotes 1. SEC. 112.

Golden v. Commissioner

39 B.T.A. 676 · United States Board of Tax Appeals · Apr 5, 1939

Cook on Corporations, sec. 534; Gibbons v. Mahon, 186 U. S. 549 ; Sabre v. Union Traction & Electric Co., 225 Fed. 601 . … J. 959; *684 Welch v. Mandeville, 1 Wheat. 233 ; Chase & Baker Co. v. National Trust & Credit Co., 215 Fed. 633 ; Greenville Savings Bank v. Lawrence, 76 Fed. 545 .