Case law

Peninsula Shipbuilding Co. v. Commissioner

5 B.T.A. 739 · United States Board of Tax Appeals · Dec 8, 1926

Peninsula Shipbuilding Co. v. Commissioner Docket No. 5741. … made by a majority of the Board) shall be conclusive on both parties.

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.

Danville Press, Inc. v. Commissioner

1 B.T.A. 1171 · United States Board of Tax Appeals · May 21, 1925

Danville Press, Inc. v. Commissioner Docket No. 900. United States Board of Tax Appeals 1 B.T.A. 1171 ; 1925 BTA LEXIS 2630 ; May 21, 1925 , decided Submitted May 4, 1925 . *2630 Henry O. … From the testimony the Board makes the following FINDINGS OF FACT. The taxpayer is an Illinois corporation.

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.

Standard Slag Co. v. Commissioner

20 B.T.A. 503 · United States Board of Tax Appeals · Aug 7, 1930

The years before the Board are 1919, 1920 and 1921. … See also Stratton’s Independence v. Howbert, 231 U. S. 399 , and Doyle v. Mitchell, 247 U. S. 179 . The petitioner has cited a number of decisions by this Board, and also Edwards v. Cuba R. R. Co., 268 U.

Cumberland Portland Cement Co. v. Commissioner

44 B.T.A. 1170 · United States Board of Tax Appeals · Aug 5, 1941

But, as the *1180 Board pointed out in Belle-Vue Manufacturing Co., 43 B. T. … A. 78, as to meet with the disapproval of the Circuit Court on review (Helvering v. Moloney Electric Co. (C. C. A., 8th Cir.), 120 Fed. (2d) 617. However, in that case and in Michigan Silica Co., 41 B. T.

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.

Meridian & T. Realty Co. v. Commissioner

44 B.T.A. 865 · United States Board of Tax Appeals · Jul 3, 1941

Commissioner v. O. P. P. Holding Corporation, 76 Fed. (2d) 11; Wiggin Terminals, Inc. v. United States, 36 Fed. (2d) 893; Commissioner v. Proctor Shop, Inc., 82 Fed. (2d) 792, afiirming 30 B. T. A. 721. … United States v. South Georgia Railway Co., 107 Fed. (2d) 3; Commissioner v. O. P. P. Holding Corporation, supra; Palmer, Stacy-Merrill, Inc. v. Commissioner, 111 Fed. (2d) 809, affirming 39 B. T.

American Manganese Steel Co. v. Commissioner

7 B.T.A. 659 · United States Board of Tax Appeals · Jul 14, 1927

AMERICAN MANGANESE STEEL CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. American Manganese Steel Co. v. Commissioner Docket No. 8145. … United States Board of Tax Appeals 7 B.T.A. 659 ; 1927 BTA LEXIS 3126 ; July 14, 1927 , Promulgated *3126 1.

Insley Mfg. Co. v. Commissioner

1 B.T.A. 1029 · United States Board of Tax Appeals · Apr 18, 1925

Co. v. Commissioner Docket No. 443. United States Board of Tax Appeals 1 B.T.A. 1029 ; 1925 BTA LEXIS 2699 ; April 18, 1925 , decided Submitted February 25, 1925 . *2699 1. … That the board of directors of the new corporation should be composed of five members, Insley, Wagner, Pfeiffer, Rasmussen, and one R. C. Kaster, the representative of the said Dollings. 5.

Gardner v. Commissioner

41 B.T.A. 679 · United States Board of Tax Appeals · Mar 29, 1940

Black : Inasmuch as the Board has recently held that the trust is not the donee of gifts, but that the beneficiaries of the trust are the donees, see Wilton Rubinstein, 41 B. T. … These assignments involve the issue of whether or not transfers to a trust for the benefit of Gilford V. Leece were in part gifts of future interests in property.

Frederick Warne & Co. v. Commissioner

1 B.T.A. 1097 · United States Board of Tax Appeals · May 5, 1925

Frederick Warne & Co. v. Commissioner Docket No. 2353. … United States Board of Tax Appeals 1 B.T.A. 1097 ; 1925 BTA LEXIS 2668 ; May 5, 1925 , decided Submitted April 16, 1925 . *2668 A foreign corporation is subject to assessment under the provisions of section 328 of the Revenue

Western States Envelope Co. v. Commissioner

10 B.T.A. 856 · United States Board of Tax Appeals · Feb 17, 1928

Canton Art Metal Co. v. Commissioner, 6 B. T. A. 446; Appeal of Washington Hotel Co., 4 B. T. A. 441; Appeal of American Express Co., 2 B. T. A. 498. … The situation here in that respect is similar to that *860 presented in Commercial Electrical Supply Co. v. Commissioner, 8 B. T. A. 986.

Delong v. Commissioner

43 B.T.A. 1185 · United States Board of Tax Appeals · Mar 27, 1941

Griffiths v. Helvering, 308 U. S. 355, 357 . We see no reason why the total consideration should not be treated as the sales price of the stock, and the excess over cost as capital gain. James Brown, 10 B. T. … Lapointe v. United States (U. S. Dist. Ct., E. Dist. Mich., Feb. 28, 1941). But for such variation the difference in presentation and record may be largely responsible.

Joseph Goodnow & Co. v. Commissioner

5 B.T.A. 1154 · United States Board of Tax Appeals · Jan 24, 1927

JOSEPH GOODNOW & CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Joseph Goodnow & Co. v. Commissioner Docket No. 7895. … Records of a special meeting held January 18, 1915, by the board of directors read as follows: A special meeting of the Board of Directors was held at the office of the Treasurer, at No. 110 State Street, Boston, Massachusetts

Youell v. Commissioner

18 B.T.A. 599 · United States Board of Tax Appeals · Dec 31, 1929

GEORGE YOUELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Youell v. Commissioner Docket No. 20756. … I, George Youell, and I, May V.

Thornton Claney Lumber Co. v. Commissioner

4 B.T.A. 434 · United States Board of Tax Appeals · Jul 27, 1926

The conclusion it seeks to impress on the Board is the result of an ingenious argument based upon an erroneous premise. … LaBelle Iron Works v. United States, 256 U. S. 377 . The deficiency for the year 1917 is $13,64-6.70 and that for 1918 is $35,297.17. Order of re-determmation will be entered accordingly.

Guaranty Trust Co. v. Commissioner

25 B.T.A. 507 · United States Board of Tax Appeals · Feb 10, 1932

Frick v. Pennsyl *512 vania, 268 U. S. 473 , 45 S. Ct. 603 , 69 L. Ed. 1058 , 42 A. L. R. 316. As Justice Holmes said in Bullen v. Wisconsin, 240 U. S. at page 631 , 36 S. Ct. 474 ( 60 L. … Reviewed by the Board. Judgment will he entered under Bule 50. GoodRIoh, Matthews, and Murdoch concur in the result.

Gallum v. Commissioner

10 B.T.A. 747 · United States Board of Tax Appeals · Feb 14, 1928

MANN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JOHN S. LAWSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. FREDERICK C. PRITZLAFF, PETITIONER, v. … BERGER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. WALTER J. BERGER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. PHILIP W. HERZOG, PETITIONER, v.

General Box Corp. v. Commissioner

22 B.T.A. 725 · United States Board of Tax Appeals · Mar 13, 1931

Knowlton v. Moore, 178 U. S. 41 ; Bate Refrigerating Co. v. Sulzberger, 157 U. S. 37 ; and Bankers’ Trust Co. v. Bowers, 295 Fed. 89 . … Keviewed by the Board. Judgment will he entered under Bule 50.