Case law

Oliver v. Commissioner

30 B.T.A. 1381 · United States Board of Tax Appeals · Jul 31, 1934

Burdett Stryker, 21 B.T.A. 561 ; David Stewart, 17 B.T.A. 604 ; Snyder v. Commissioner, 54 Fed. (2d) 57, affirming John A. Snyder, 20 B.T.A. 778 . … This Board thought otherwise.

Kidder v. Commissioner

30 B.T.A. 59 · United States Board of Tax Appeals · Mar 13, 1934

V-l, p. 12. A sale of trust certificates under circumstances such as existed in this case would not result in an actual loss. … Reviewed by the Board. Judgment will be entered for the respondent.

Producers' Fuel Co. v. Commissioner

1 B.T.A. 202 · United States Board of Tax Appeals · Dec 18, 1924

Producers' Fuel Co. v. Commissioner Docket No. 159. … In Donovan v.

Gardner Governor Co. v. Commissioner

27 B.T.A. 1171 · United States Board of Tax Appeals · Apr 14, 1933

Though terminology is not conclusive of the intent of the parties (Alger-Sullivan Lumber Co. v. Commissioner, 57 Fed. (2d) 3), if supported by similar collateral evidences and circumstances it is a fact of weight. … Reviewed by the Board. Decision will he entered under Rule 50.

Moir v. Commissioner

14 B.T.A. 23 · United States Board of Tax Appeals · Nov 6, 1928

See also, as to the technical position of the parties under an escrow in Illinois Phennagar v. … Eeviewed by the Board. Judgment will he entered under Bule 50.

Sullivan v. Commissioner

16 B.T.A. 1347 · United States Board of Tax Appeals · Jul 17, 1929

SULLIVAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sullivan v. Commissioner Docket Nos. 29063, 33742. … He has been treasurer and chairman of the board of directors of the corporation since its organization.

Memphis Linotype Printing Co. v. Commissioner

9 B.T.A. 666 · United States Board of Tax Appeals · Dec 19, 1927

MEMPHIS LINOTYPE PRINTING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Memphis Linotype Printing Co. v. Commissioner Docket No. 7072. … United States Board of Tax Appeals 9 B.T.A. 666 ; 1927 BTA LEXIS 2539 ; December 19, 1927 , Promulgated *2539 Upon the evidence submitted, additional salaries claimed as a deduction for 1918 disallowed. O. R.

First Nat'l Sec. Co. v. Commissioner

20 B.T.A. 999 · United States Board of Tax Appeals · Sep 25, 1930

V. Board, 14 B. T. A. 374, 393; and John T. Kennedy, 16 B. T. A. 1372, 1390. Judgment will be entered for the resfondent.

Textile Mill Supply Co. v. Commissioner

8 B.T.A. 145 · United States Board of Tax Appeals · Sep 19, 1927

TEXTILE MILL SUPPLY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Textile Mill Supply Co. v. Commissioner Docket No. 10382. … Reviewed by the Board. Decision will be entered on 15 days' notice, under Rule 50.

Standard Island Creek Coal Co. v. Commissioner

28 B.T.A. 690 · United States Board of Tax Appeals · Jul 18, 1933

Respondent has claimed, in the alternative, that said item should be included in income for the year 1928 and said claim is now pending before the Board in the case of North American Coal Corporation v.

Astor v. Commissioner

31 B.T.A. 1009 · United States Board of Tax Appeals · Jan 9, 1935

WALDORF ASTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Astor v. Commissioner Docket No. 64269. … Two issues are presented for decision by the Board. The facts have been stipulated.

Eldredge v. Commissioner

18 B.T.A. 194 · United States Board of Tax Appeals · Nov 12, 1929

ELDREDGE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Eldredge v. Commissioner Docket No. 20541. … Reviewed by the Board. Judgment will be entered under Rule 50.

Crowell v. Commissioner

21 B.T.A. 849 · United States Board of Tax Appeals · Dec 22, 1930

Brown et al., 18 B. T. A. 859. “ It is immaterial whether the Commissioner proceeded upon the wrong theory in determining the deficiencies. … Richardson v. Shaw, 209 U. S. 365 ; Gorman v. Littlefield, 229 U. S. 19 ; Duel v. Hollins, 241 U. S. 523 ; In re Cawley, 29 Fed. (2d) 593.”

G. M. Standifer Constr. Corp. v. Commissioner

4 B.T.A. 525 · United States Board of Tax Appeals · Jul 30, 1926

Corp. v. Commissioner Docket No. 5550. United States Board of Tax Appeals 4 B.T.A. 525 ; 1926 BTA LEXIS 2246 ; July 30, 1926 , Decided *2246 *525 1. … V. Jones and L. B. Menefee likewise guaranteed the performance of contract 503-SC.

Gideon-Anderson Co. v. Commissioner

20 B.T.A. 106 · United States Board of Tax Appeals · Jun 19, 1930

Petition was filed with the Board on February 17, 1927. … United States v. Capps Mfg. Co., 15 Fed.(2d) 528 ; Grennell v. Detroit Gas Co., 112 Mich. 70 ; 70 N.W. 413 ; McWilliams v. Excelsior Coal Co., 298 Fed.884 ; Swing v.

Little v. Commissioner

20 B.T.A. 1042 · United States Board of Tax Appeals · Sep 29, 1930

LITTLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Little v. Commissioner Docket No. 26035. … Little 10,000 Hoke V. Smith 2,000 Hoke V. Smith 2,000 C. A. Hatcher 5,000 J. Gregory Johnson 19,000 C. D. Little 10,000 Bills receivable 6,000 Total 50,000 Total 50,000 On November 21, 1923, a Mr.

Hart v. Commissioner

4 B.T.A. 254 · United States Board of Tax Appeals · Jun 28, 1926

Hart v. Commissioner Docket No. 9954. United States Board of Tax Appeals 4 B.T.A. 254 ; 1926 BTA LEXIS 2336 ; June 28, 1926 , Decided Submitted April 12, 1926 . *2336 George M. Powell, C.P.A., for the petitioner. D. D. … The Board is *255 charged with the duty of making findings of fact, and in the absence of any proof its findings must be confined to those facts which are pleaded in the petition and not denied by the answer, or which are

Columbia Oil & Gas Co. v. Commissioner

41 B.T.A. 38 · United States Board of Tax Appeals · Jan 10, 1940

Schumacher Wall Board Corporation, 93 Fed. (2d) 79; United Light Power Co., 38 B. T. A. 477; affd., 105 Fed. (2d) 866; Sam Pickard, 40 B. T. A. 258. Since the decision of Halliburton v. … Reviewed by the Board. Decision will be entered under Rule 50.

National Concrete Co. v. Commissioner

3 B.T.A. 777 · United States Board of Tax Appeals · Feb 17, 1926

The divulging of the names is not sought by the Commissioner or the Board simply to gratify curiosity or to solve a mystery, but to properly authenticate the expenditures. … Co. v. United States, 254 U. S. 141, 143 , “Men must turn square corners when they deal with the Government.”

Ehrman v. Commissioner

41 B.T.A. 652 · United States Board of Tax Appeals · Mar 22, 1940

Commissioner, 77 Fed. (2d) 599; Richards v. Commissioner, 81 Fed. (2d) 369; Welch v. Solomon, 99 Fed. (2d) 41; and Commissioner v. Boeing, 106 Fed. (2d) 305. … Phipps v. Commissioner rests upon the conclusion that the transactions in the taxable year were not sufficient to constitute doing business, and Pope v.