Case law

Clark v. Commissioner

24 B.T.A. 1235 · United States Board of Tax Appeals · Dec 22, 1931

A. 651; affd., Commissioner v. Widener, 33 Fed. (2d) 833; and Margaret E. Amory, 22 B. T. … 1924, and 1925 in the operation of bis breeding and racing stables and also in determining that decedent realized a profit in 1923 upon the sale of stock in the Cleveland Electric Illuminating Company. • Reviewed by the Board

Gardiner & Wells Co. v. Commissioner

17 B.T.A. 723 · United States Board of Tax Appeals · Sep 30, 1929

GARDINER & WELLS CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Gardiner & Wells Co. v. Commissioner Docket No. 16838. … Reviewed by the Board. Judgment will be entered for the respondent.

Big Rapids Elec. Co. v. Commissioner

9 B.T.A. 737 · United States Board of Tax Appeals · Dec 21, 1927

Reviewed by the Board. Judgment will be entered on 15 days’’ notice, v/nder Rule 50.

Gress Mfg. Co. v. Commissioner

3 B.T.A. 977 · United States Board of Tax Appeals · Feb 24, 1926

Co. v. Commissioner Docket No. 3102. United States Board of Tax Appeals 3 B.T.A. 977 ; 1926 BTA LEXIS 2514 ; February 24, 1926 , Decided Submitted October 19, 1925 . *2514 1. … The Board has no jurisdiction to consider whether any overpayment of tax has been made in any year not considered in the deficiency letter for the purpose of determining a credit to be applied against the deficiency determined

Plainfield Grain Co. v. Commissioner

9 B.T.A. 446 · United States Board of Tax Appeals · Dec 1, 1927

PLAINFIELD GRAIN CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Plainfield Grain Co. v. Commissioner Docket No. 1420. … United States Board of Tax Appeals 9 B.T.A. 446 ; 1927 BTA LEXIS 2582 ; December 1, 1927 , Promulgated *2582 W. H. Cryder, Esq., for the petitioner. Thomas P. Dudley, Jr., Esq., for the respondent.

Forstner Chain Corp. v. Commissioner

45 B.T.A. 19 · United States Board of Tax Appeals · Sep 4, 1941

FORSTNER CHAIN CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Forstner Chain Corp. v. Commissioner Docket No. 104998. … United States Board of Tax Appeals 45 B.T.A. 19 ; 1941 BTA LEXIS 1190 ; September 4, 1941 , Promulgated *1190 Pursuant to a resolution of the board of directors the petitioner, in 1936, offered to purchase from its three

Electro Dental Parlor v. Commissioner

2 B.T.A. 83 · United States Board of Tax Appeals · Jun 18, 1925

Electro Dental Parlor v. Commissioner Docket No. 626. United States Board of Tax Appeals 2 B.T.A. 83 ; 1925 BTA LEXIS 2545 ; June 18, 1925 , Decided Submitted May 26, 1925 . *2545 J. W. A. … From the pleadings and the stipulation presented at the hearing, the Board makes the following FINDINGS OF FACT. 1.

Hidalgo Steel Co. v. Commissioner

8 B.T.A. 76 · United States Board of Tax Appeals · Sep 16, 1927

A. 202; Raleigh Smokeless Fuel Co. v. Commissioner, 6 B. T. A. 381. … Reviewed by the Board. * Judgment will be entered for the respondent.

Hotel Patten Co. v. Commissioner

13 B.T.A. 943 · United States Board of Tax Appeals · Oct 12, 1928

POUND HOTEL CO., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Hotel Patten Co. v. Commissioner Docket No. 5792. … and the appeal is pending before the Board at the time of the enactment of this Act, the Board shall have jurisdiction of the appeal.

Dunson Mills v. Commissioner

10 B.T.A. 1150 · United States Board of Tax Appeals · Mar 2, 1928

revenue, advising the petitioner that its claim for abatement had been considered by the Commissioner of Internal Revenue and rejected, did not constitute a notice of deficiency as to which a petition could be filed with this Board … ’s position is not sound, it is obvious that the proposed deficiency is barred by the provisions of section 250(d) of the Revenue Act of 1921 since, under the decision of the Supreme Court of the United States in Bowers v.

Farmers Elevator Co. v. Commissioner

13 B.T.A. 1079 · United States Board of Tax Appeals · Oct 17, 1928

FARMERS ELEVATOR CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Farmers Elevator Co. v. Commissioner Docket No. 13424. … The following stipulation of the parties is accepted and adopted by the Board as its FINDINGS OF FACT. 1. Petitioner is a Minnesota corporation with its principal office at Brewster. 2.

Allyne-Zerk Co. v. Commissioner

29 B.T.A. 1194 · United States Board of Tax Appeals · Feb 23, 1934

The Circuit Court of Appeals, in Commissioner v. S. A. … The majority also relies on Houghton & Dutton Co., 26 B.T.A. 52 , in which the Board followed the Circuit Court of Appeals in S. A. Woods Machine Co., the instant case arising in the same circuit, and Commissioner v.

Coastwise Transp. Corp. v. Commissioner

22 B.T.A. 373 · United States Board of Tax Appeals · Feb 25, 1931

COASTWISE TRANSPORTATION CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Coastwise Transp. Corp. v. Commissioner Docket No. 39916. … No appeal was taken by the Commissioner from the , decision or from the later decisions of the Board to the same effect.

McDonald v. Commissioner

28 B.T.A. 64 · United States Board of Tax Appeals · May 11, 1933

Murdock : A jurisdictional question was suggested by the Board Member at the hearing and the parties were requested to. up by proof of all pertinent facts. … Robertson, 5 B.T.A. 748 , and Robinson v. Commissioner, 59 Fed. (2d) 1008. Furthermore, the present case is an appropriate one for the application of such a theory, if the theory is sound in principle.

Richards v. Commissioner

13 B.T.A. 1279 · United States Board of Tax Appeals · Oct 30, 1928

RICHARDS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Richards v. Commissioner Docket No. 13869. … We therefore find that the Board has jurisdiction to determine the appeal in this case.

National Grocery Co. v. Commissioner

35 B.T.A. 163 · United States Board of Tax Appeals · Dec 9, 1936

NATIONAL GROCERY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT National Grocery Co. v. Commissioner Docket No. 76600. … In the first case which came before this Board under the section as originally enacted (; affd., ; certiorari denied, ), both this Board and the Circuit Court upon appeal properly stressed the importance of establishing by

Southern Bell Tel. & Tel Co. v. Commissioner

34 B.T.A. 540 · United States Board of Tax Appeals · May 6, 1936

No petition was filed with the Board by the Fayette Co. from the above determinations. The said assessment lists were duly received by the collector for the district of Kentucky. … Motter v. Patterson, 68 Fed. (2d) 252.

Davison v. Commissioner

21 B.T.A. 251 · United States Board of Tax Appeals · Nov 10, 1930

DAVISON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Davison v. Commissioner Docket Nos. 40749, 47723. … United States Board of Tax Appeals 21 B.T.A. 251 ; 1930 BTA LEXIS 1885 ; November 10, 1930 , Promulgated *1885 1.

Smith v. Commissioner

4 B.T.A. 385 · United States Board of Tax Appeals · Jul 26, 1926

Smith v. Commissioner Docket No. 3262. United States Board of Tax Appeals 4 B.T.A. 385 ; 1926 BTA LEXIS 2296 ; July 26, 1926 , Decided *2296 1. … A similar question was before the Board in the case of the , wherein it was held that the separate returns filed by husband and wife were merely amendments of the original joint return and related back to and become a part

Durfee Mineral Co. v. Commissioner

7 B.T.A. 231 · United States Board of Tax Appeals · Jun 9, 1927

Durfee Mineral Co. v. Commissioner Docket No. 1133. … And see Smith v. Anderson, L.R., 15 Ch.Div. 24&. It results that Crocker v.