Case law

North Wayne Tool Co. v. Commissioner

2 B.T.A. 366 · United States Board of Tax Appeals · Jul 15, 1925

North Wayne Tool Co. v. Commissioner Docket No. 1897. … From the pleadings and stipulation the Board makes the following FINDINGS OF FACT. The taxpayer is a Maine corporation with its principal office at Hallowell.

Sumpter Valley Ry. v. Commissioner

10 B.T.A. 1325 · United States Board of Tax Appeals · Mar 13, 1928

SUMPTER VALLEY RAILWAY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sumpter Valley Ry. v. Commissioner Docket No. 13145. … From this the taxpayer proceeded before this Board in due course.

Newton v. Commissioner

7 B.T.A. 1153 · United States Board of Tax Appeals · Aug 23, 1927

A like ruling was made by the Board in Fridolin Pabst v. Commissioner, 6 B. T. A. 843. See also Harry J. Gutman v. Commissioner, 7 B. T. A. 500.

Hamilton & Chambers Co. v. Commissioner

1 B.T.A. 694 · United States Board of Tax Appeals · Feb 28, 1925

Hamilton & Chambers Co. v. Commissioner Docket No. 131. … From the foregoing the Board makes the following *2842 FINDINGS OF FACT.

Dils Bros. & Co. v. Commissioner

2 B.T.A. 983 · United States Board of Tax Appeals · Oct 26, 1925

. & Co. v. Commissioner Docket No. 3575. United States Board of Tax Appeals 2 B.T.A. 983 ; 1925 BTA LEXIS 2197 ; October 26, 1925 , Decided Submitted July 20, 1925 . *2197 Harold R. Young, Esq., for the taxpayer. … The resolutions of the board of directors held in March, 1917, and 1918, immediately upon the adjournment of the stockholders' meetings, were as follows: On motion, duly seconded, of Mary D.

Peerless Engraving Co. v. Commissioner

3 B.T.A. 464 · United States Board of Tax Appeals · Jan 26, 1926

Peerless Engraving Co. v. Commissioner Docket No. 3626. … United States Board of Tax Appeals 3 B.T.A. 464 ; 1926 BTA LEXIS 2660 ; January 26, 1926 , Decided Submitted October 20, 1925 . *2660 Taxpayer was not, during 1919 and 1920, a personal service corporation. Charles R.

Pictorial Review Co. v. Commissioner

5 B.T.A. 416 · United States Board of Tax Appeals · Nov 10, 1926

Pictorial Review Co. v. Commissioner Docket Nos. 4487, 6661, 11303. United States Board of Tax Appeals 5 B.T.A. 416 ; 1926 BTA LEXIS 2862 ; November 10, 1926 , Decided *2862 1. … On March 19, 1917, the board of directors of the petitioner corporation declared an extra dividend equal to 50 per cent of the capital stock of the company, which was on March 21, 1917, paid to the stockholders of record.

Bilicke v. Commissioner

20 B.T.A. 784 · United States Board of Tax Appeals · Sep 12, 1930

V. Board, 14 B. T. A. 374; William H. Mullins, 14 B. T. A. 426; Hans Pederson, 14 B. T. A. 1089. We think that this principle is basic to the' solution of the question now under consideration. … Reviewed by the Board. Decision mil be entered v/nder Bule 50.

Lapsley v. Commissioner

44 B.T.A. 1105 · United States Board of Tax Appeals · Jul 24, 1941

He cites Helvering v. Hammel, 311 U. S. 504 ; Electro-Chemical Engraving Co. v. Commissioner, 311 U. S. 513 ; Welch v. Street, 116 Fed. (2d) 953; and Edward F. C. McLaughlin, 43 B. T. … Rogers v. Commissioner, 103 Fed. (2d) 790, affirming Betty Rogers, 37 B. T. A. 897), but abandoned the property to the mortgagee (W. W. Hoffman, supra, and Commissioner v. Hoffman, supra.)

Tyson v. Commissioner

20 B.T.A. 597 · United States Board of Tax Appeals · Aug 26, 1930

We think the evidence brings the petitioner within the class of associations .provided for in the statute and recognized in Hecht v. Malley, 265 U. S. 144 ; and Burk-Waggoner Oil Assn. v. Hopkins, 269 U. S. 110 . … Reviewed by the Board. Yan Fossan dissents. Judgment will Toe entered under Rule 50.

Clark v. Commissioner

47 B.T.A. 865 · United States Board of Tax Appeals · Oct 9, 1942

EDITH EVELYN CLARK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Clark v. Commissioner Docket No. 103989. … Reviewed by the Board. Decision will be entered for the petitioner. TURNER TURNER, dissenting: In my opinion, the Board has confused the question here involved and decided another.

Mackay v. Commissioner

33 B.T.A. 765 · United States Board of Tax Appeals · Dec 20, 1935

The Board was affirmed by the Circuit Court of Appeals at 74 Fed. (2d) 242. The Supreme Court handed down its decision November 11, 1985 (Helvering v. City Bank Farmers Trust Co., Trustee, 296 U. … But the trust in Helvering v.

Pennsylvania Co. for Ins. etc. v. Commissioner

19 B.T.A. 699 · United States Board of Tax Appeals · Apr 24, 1930

As we have seen in Juvenal v. … A. 23; Davidson & Case Lumber Co. v. Motter, 14 Fed. (2d) 137. ^Reviewed by the Board. Judgment will be entered for the respondent.

Fontana Power Co. v. Commissioner

43 B.T.A. 1090 · United States Board of Tax Appeals · Mar 21, 1941

Justice Frankfurter in his opinion in Helvering v. Hallock, 309 U. … In a majority of the cases of this nature which have come before this Board the instrument issued by the corporation has been some form of stock certificate.

Newark Milk & Cream Co. v. Commissioner

10 B.T.A. 683 · United States Board of Tax Appeals · Feb 13, 1928

NEWARK MILK & CREAM CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Newark Milk & Cream Co. v. Commissioner Docket No. 14191. … The operations of the petitioner in each town were subject to the supervision of the board of health of such town. *4051 Each board of health made regular inspections of the petitioner's operations within its jurisdiction

Stryker v. Commissioner

21 B.T.A. 561 · United States Board of Tax Appeals · Dec 3, 1930

Richardson v. Shaw, 209 U. S. 365 ; Gorman v. Littleield, 229 U. S. 19 ; Duel v. Hollins, 241 U. S. 523 ; In re Cawley, 29 Fed. (2d) 593. … Reviewed by the Board. Judgment will be entered for the respondent.

Baboquivari Cattle Co. v. Commissioner

47 B.T.A. 129 · United States Board of Tax Appeals · Jun 16, 1942

Ltd. v. Johnson, 285 U. S. 480 ; Sun-Herald Corporation v. Duggan, 73 Fed. (2d) 298; United States v. Stewart, 311 U. S. 60 . … The cited case has been followed many times by the courts and this Board. In Liberty Light & Power Co., 4 B. T.

Insull v. Commissioner

32 B.T.A. 1070 · United States Board of Tax Appeals · Aug 1, 1935

SAMUEL INSULL, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. MARGARET A. INSULL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. SAMUEL INSULL, PETITIONER, v. … Reviewed by the Board. Judgment will be entered under Rule 50.

Wigwam Amusement Co. v. Commissioner

1 B.T.A. 335 · United States Board of Tax Appeals · Jan 16, 1925

Wigwam Amusement Co. v. Commissioner Docket No. 180. … An appeal from the determination of the Commissioner was filed with this Board on September 13, 1924.

Keystone Table Co. v. Commissioner

1 B.T.A. 382 · United States Board of Tax Appeals · Jan 27, 1925

Keystone Table Co. v. Commissioner Docket No. 533. … From the evidence presented at the hearing the Board makes the following FINDINGS OF FACT. 1. The taxpayer is a Pennsylvania corporation engaged in the manufacture of furniture at Mount Wolf, Pa.