Case law

Brown v. Commissioner

22 B.T.A. 678 · United States Board of Tax Appeals · Mar 11, 1931

These duties include many which can not be definitely related to any particular line of business, such as the appointment and removal of local agents, representation of the firm’s principals on the Pacific Board of Fire Underwriters … See also, Consolidated Tea Co. v. Bowers, 19 Fed. (2d) 382; and Malleable Iron Range Co. v. United States, 62 Ct. Cls. 425. Judgment will be entered under Rule 50.

Brown v. Commissioner

11 B.T.A. 1203 · United States Board of Tax Appeals · May 8, 1928

Brown v. Commissioner

1 B.T.A. 446 · United States Board of Tax Appeals · Jan 30, 1925

Brown v. Commissioner

38 B.T.A. 298 · United States Board of Tax Appeals · Aug 10, 1938

This case and the case of Helvering v. Grinnell, 294 U. … Stratton v. United States, 50 Fed. (2d) 48, decided by the Circuit Court of Appeals for the First Circuit some four years prior to the decision of Helvering v. Grinnell, supra, is squarely in point.

Brown & Haley v. Commissioner

21 B.T.A. 752 · United States Board of Tax Appeals · Dec 17, 1930

A. 545; Model Dairy Co. v. Com missioner, 36 Fed. (2d) 768; Botany Worsted Mills v. United States, 278 U. S. 282 . … In determining the reasonableness of salaries the Board has considered duties discharged, responsibilities assumed, volume of business handled, capital employed, gross income, and net income.

Brown & Ives v. Commissioner

2 B.T.A. 936 · United States Board of Tax Appeals · Oct 20, 1925

This Board has no power to equalize or reduce taxes and must determine cases in accordance with the statute. Congress alone can remedy the situation to which the taxpayers object.

Brown v. Commissioner (A)

4 B.T.A. 1129 · United States Board of Tax Appeals · Sep 27, 1926

Board v. Commissioner

18 B.T.A. 650 · United States Board of Tax Appeals · Jan 7, 1930

Board v. Commissioner

14 B.T.A. 374 · United States Board of Tax Appeals · Nov 20, 1928

This same transaction was before the Board in V. J. Bulleit, 3 B. T. A. 631. … In support of this position, petitioner cites United States v.

Brown-Wheeler Co. v. Commissioner

21 B.T.A. 755 · United States Board of Tax Appeals · Dec 17, 1930

Brown-Crummer Co. v. Commissioner

19 B.T.A. 750 · United States Board of Tax Appeals · Apr 28, 1930

attorneys for the petitioner and respondent that no evidence be introduced, but that the issues herein presented be submitted, considered and decided upon the transcript of the record made in First National Bank in Wichita v. … Reviewed by the Board. Decision will be entered, wider Bule 50. Smith and Trammell dissent.

Brown Shoe Co. v. Commissioner

45 B.T.A. 212 · United States Board of Tax Appeals · Sep 26, 1941

If it was in fact a capital transaction, i. e., if the shares were acquired or parted with in connection with a readjustment of the capital structure of the corporation, the Board rule applies. Doyle v. Mitchell Bros. … Reviewed by the Board. Decision will be entered under Rule 50. Murdock dissents. Art. 22 (a)-16.

M. Brown & Co. v. Commissioner

9 B.T.A. 753 · United States Board of Tax Appeals · Dec 21, 1927

Brown Lumber Co. v. Commissioner

9 B.T.A. 719 · United States Board of Tax Appeals · Dec 20, 1927

R., and where it was argued that f. o. b. was only a factor in the selling price, the court said: * * * “ Free on board ” has acquired a settled judicial meaning. Vogt v. Schienebeck (Wis.) 100 N. W. 820 , 67 L. R. … In support of its position, petitioner cites Richardson Lumber Co. v.

Brown Agency, Inc. v. Commissioner

21 B.T.A. 1111 · United States Board of Tax Appeals · Jan 12, 1931

hearing the respondent admitted that evidence adduced at the hearing, which had never been previously put before the respondent, lead unavoidably to the conclusion that the officers’ salaries were duly authorized by the board

Ennis-Brown Co. v. Commissioner

10 B.T.A. 1248 · United States Board of Tax Appeals · Mar 8, 1928

The opinion of the Board in Butler's Warehouses, Inc., 1 B. T. A., 851, contains quotations from the Congressional Record showing the intent of Congress in enacting section 204 of the Revenue Act of 1918. … Auburn & Alton Coal Co., v. United States, 61 Ct. Cls. 438. This petitioner’s fiscal year 1919 began September 1, 1918, prior to the period designated by the special relief provisions of section 204 of the 1918 Act.

Brown v. Commissioner

21 B.T.A. 752 · United States Board of Tax Appeals · Dec 17, 1930

A. 545; Model Dairy Co. v. Com missioner, 36 Fed. (2d) 768; Botany Worsted Mills v. United States, 278 U. S. 282 . … In determining the reasonableness of salaries the Board has considered duties discharged, responsibilities assumed, volume of business handled, capital employed, gross income, and net income.

Brown v. Commissioner

20 B.T.A. 47 · United States Board of Tax Appeals · Jun 13, 1930

See Vidal v. Girard, 43 U. S. 126, 196 , and footnote to Wheeler v. Smith, 50 U. S. 55 ; In re Dulles’ Estate, 218 Pa. 162 ; 67 Atl. 49 . … Bekins v. Smith, 37 Cal. App. 222 ; 174 Pac. 96 .

Board v. Commissioner

14 B.T.A. 374 · United States Board of Tax Appeals · Nov 20, 1928

This same transaction was before the Board in V. J. Bulleit, 3 B. T. A. 631. … In support of this position, petitioner cites United States v.

Board v. Commissioner

18 B.T.A. 650 · United States Board of Tax Appeals · Jan 7, 1930