Case law

Sinsheimer v. Commissioner

7 B.T.A. 1099 · United States Board of Tax Appeals · Aug 22, 1927

SINSHEIMER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sinsheimer v. Commissioner Docket No. 11068. … Petitioner's adopted son was with his mother most of this time and subsequently was in a boarding school.

Sanitary Earthenware Specialty Co. v. Commissioner

19 B.T.A. 641 · United States Board of Tax Appeals · Apr 22, 1930

SANITARY EARTHENWARE SPECIALTY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sanitary Earthenware Specialty Co. v. Commissioner Docket Nos. 31161, 31162. … This Board has heretofore decided the question here involved adversely to the contention of the petitioner.

Liberty Light & Power Co. v. Commissioner

4 B.T.A. 155 · United States Board of Tax Appeals · Jun 21, 1926

The Board is without information from the Commissioner as to the theory upon which he predicated his decision that this property constituted taxable income. … S. 156 , and Weiss v. Stearn, 265 U. S. 242 ; Bowers v. Kerbaugh-Empire Co. , 271 U. S. 170 . In the case of Cuba R. R. Co. v.

Fajardo Sugar Co. v. Commissioner

20 B.T.A. 980 · United States Board of Tax Appeals · Sep 25, 1930

See Western Bank v. Armstrong, 152 U. S. 346 ; Auten v. National Bank, supra; Aldrich v. Chemical National Bank, 176 U. S. 618 . … In this office its board of directors met monthly and from it that board and the officers conducted and managed the general affairs and policy of the company; there its president and secretary and assistant treasurer had

Hubinger v. Commissioner

13 B.T.A. 960 · United States Board of Tax Appeals · Oct 12, 1928

HUBINGER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Hubinger v. Commissioner Docket No. 12437. … The petitioner thereupon duly filed its appeal with the Board of Tax Appeals. OPINION.

International Banding Machine Co. v. Commissioner

12 B.T.A. 1062 · United States Board of Tax Appeals · Jun 30, 1928

INTERNATIONAL BANDING MACHINE CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. International Banding Machine Co. v. Commissioner Docket No. 13744. … The patent is basic and was sustained *3414 by the United States Circuit Court of Appeals, Second Circuit, in International Banding Machine Co. v. American Bander Co., 9 Fed.(2d) 606 .

Mitchell v. Commissioner

40 B.T.A. 424 · United States Board of Tax Appeals · Aug 15, 1939

White v. United States, 20 Fed. Supp. 623; M. Rea Gano, 19 B. T. A. 518; Frank A. Weinstein, 33 B. T. A. 105; Charles E. Mitchell, supra. … A. 702; affd., 76 Fed. (2d) 670; followed by the Board as recently as Henry Hudson, 39 B. T. A. 1075.

Wyche v. Commissioner

36 B.T.A. 414 · United States Board of Tax Appeals · Aug 4, 1937

We do not think Burnet v. Logan, supra, and Board and court cases which have followed it go so far. … In the Burnet v.

Douglas v. Commissioner

1 B.T.A. 372 · United States Board of Tax Appeals · Jan 27, 1925

Douglas v. Commissioner Docket No. 288. United States Board of Tax Appeals 1 B.T.A. 372 ; 1925 BTA LEXIS 2942 ; January 27, 1925 , decided Submitted November 24, 1924 . *2942 1. … V.

Terrell v. Commissioner

7 B.T.A. 773 · United States Board of Tax Appeals · Jul 29, 1927

All of the foregoing contentions, with the exception of the very last one, have already been considered by this Board in the Appeal of James P. McKenna, 1 B. T. … Steinberg v. United States, 14 Fed. (2d) 564; 5 Am. Fed. Tax Rep. 6160; United States v. Sullivan, 274 U. S. 259 . On the last contention regarding the first assignment of error the petitioner has failed in his proof.

Humbert v. Commissioner

24 B.T.A. 828 · United States Board of Tax Appeals · Nov 17, 1931

HUMBERT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ARTHUR M. REIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Humbert v. Commissioner Docket Nos. 37052, 37053. … Reviewed by the Board. Judgment will be entered in each proceeding for the respondent.

Jordan Marsh Co. v. Commissioner

3 B.T.A. 553 · United States Board of Tax Appeals · Feb 3, 1926

Jordan Marsh Co. v. Commissioner Docket Nos. 4458, 4459. … The price to be paid under said options shall be fixed by the board of directors of the Jordan Marsh Company, on application of the seller or of any stockholder desiring to purchase.

Harmount v. Commissioner

16 B.T.A. 767 · United States Board of Tax Appeals · May 28, 1929

TIMMONS HARMOUNT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Harmount v. Commissioner Docket No. 15569. … The First National Bank of Chillicothe, before making any loan, examined the collateral offered as security and a report thereon was made to the board of directors.

Reed v. Commissioner

24 B.T.A. 166 · United States Board of Tax Appeals · Sep 25, 1931

In Brown v. Powell, 130 Miss. 496 ; 94 So. 457 (1923), the Supreme Court of Mississippi had before it the exact question presented in the instant case. … Under the rule laid down in Chase National Bank v. United States, 278 U. S. 827 ; Saltonstall v. Saltonstall, 276 U. S. 260 ; and Reinecke v. Northern Trust Co., 278 U.

Superheater Co. v. Commissioner

12 B.T.A. 5 · United States Board of Tax Appeals · May 18, 1928

THE SUPERHEATER CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Superheater Co. v. Commissioner Docket No. 8383. … The authorization for the issuance of the 25,000 shares was made at the board of directors' meeting of the Schmidt Superheating Co., Ltd., held July 25, 1919.

Accounting & Tabulating Machine Corp. v. Commissioner

21 B.T.A. 951 · United States Board of Tax Appeals · Dec 29, 1930

ACCOUNTING & TABULATING MACHINE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Accounting & Tabulating Machine Corp. v. Commissioner Docket No. 30137. … Reviewed by the Board. Judgment will be entered under Rule 50.

Peterson v. Commissioner

42 B.T.A. 102 · United States Board of Tax Appeals · Jun 18, 1940

He cites Higgins v. Smith, 308 U. S. 473 , and Helvering v. Clifford, 309 U. S. 331 , as authority for his determination of the existence of this premise here. … Reviewed by the Board. Decisions will he entered for the 'petitioners.

Wigginton v. Commissioner

9 B.T.A. 1030 · United States Board of Tax Appeals · Jan 3, 1928

WIGGINTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Wigginton v. Commissioner Docket No. 11425. … of Directors of the said Company or by a Committee of said Board of Directors or by a competent Auditor or in such other way as may be directed by said Board: It being understood and agreed that the amount of said additional

American S.S. Owners Mut. Protection & Indem. Asso. v. Commissioner

46 B.T.A. 275 · United States Board of Tax Appeals · Feb 6, 1942

Expenses (other than wages) reasonably incurred in necessarily repatriating any member of the crew or any other person employed on board an entered steamship; provided, however, that no member shall be entitled to recover … Helvering v. Oregon Mutual Life Insurance Co., 311 U. S. 267 ; Valley Waste Disposal Co., 38 B. T. A. 452; Board of Fire Underwriters of the City of Duluth, 26 B. T. A. 860; Growers Cold Storage Co., 17 B. T. A. 1279.

Kohler v. Commissioner

37 B.T.A. 1019 · United States Board of Tax Appeals · Jun 10, 1938

Burnet v. Houston, 283 U. S. 223 . … But that question need receive no consideration by the Board because the Board has nothing to do with the assessment and collection of the taxes.