Case law

Lang v. Commissioner

32 B.T.A. 522 · United States Board of Tax Appeals · Apr 30, 1935

that when demand was made upon it a debtor-creditor relationship sprang into existence; and that upon failure to obtain reimbursement it was entitled to take a deduction of $237,000 as a bad debt upon the theory of Shiman v. … Be vie wed by the Board. Judgment will be entered for the respondent.

North American Coal Corp. v. Commissioner

28 B.T.A. 807 · United States Board of Tax Appeals · Aug 3, 1933

v. … Lucas v. American Code Co., 280 U.S. 445 ; Llewellyn v. Electric Reduction Co., 275 U.S. 243 ; Consolidated Tea Co. v. Bowers, 19 Fed. (2d) 382; Central Trust Co. v.

C. Willenborg & Co. v. Commissioner

5 B.T.A. 788 · United States Board of Tax Appeals · Dec 14, 1926

Willenborg & Co. v. Commissioner Docket No. 6334. … Upon authority of the decisions of this Board in the , and , the Board is without jurisdiction to make redetermination in those years.

Mutual Chem. Co. v. Commissioner

12 B.T.A. 578 · United States Board of Tax Appeals · Jun 13, 1928

The petitioner’s counsel contends that as a matter of law the term “ goods on hand ” as used in the regulations does not include raw materials and he cites as authority for his contention Cumpston v. Haigh, 2 Bing. N. … Reviewed by the Board. Recomputation of the deficiency should be made under Rule 6£(c).

Barker-Jennings Hardware Corp. v. Commissioner

4 B.T.A. 20 · United States Board of Tax Appeals · Apr 21, 1926

Barker-Jennings Hardware Corp. v. Commissioner Docket No. 5265. United States Board of Tax Appeals 4 B.T.A. 20 ; 1926 BTA LEXIS 2397 ; April 21, 1926 , Decided Submitted February 5, 1926 . *2397 1. … His determination is clearly in accordance with the decision of the Board in .

Lightning Creek Oil & Gas Co. v. Commissioner

9 B.T.A. 1150 · United States Board of Tax Appeals · Jan 11, 1928

AND CONSOLIDATED COMPANY, CAREY OIL & GAS CO., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Lightning Creek Oil & Gas Co. v. Commissioner Docket Nos. 8584, 23204. … Reviewed by the Board. Judgment will be entered on 15 days' notice, under Rule 50.

Ellis v. Commissioner

15 B.T.A. 1075 · United States Board of Tax Appeals · Mar 26, 1929

ELLIS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Ellis v. Commissioner Docket No. 26136. … Reviewed by the Board. Decision will be entered under Rule 50.

Zimmerman v. Commissioner

2 B.T.A. 667 · United States Board of Tax Appeals · Sep 28, 1925

Zimmerman v. Commissioner Docket No. 2145. United States Board of Tax Appeals 2 B.T.A. 667 ; 1925 BTA LEXIS 2329 ; September 28, 1925 , Decided Submitted April 29, 1925 . *2329 James Walton, Esq., and J. M. … From the pleadings and oral and documentary evidence presented at the hearing the Board makes the following. FINDINGS OF FACT. The taxpayer is a resident of Butler, Pa.

John F. Campbell Co. v. Commissioner

15 B.T.A. 458 · United States Board of Tax Appeals · Feb 15, 1929

CAMPBELL CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. John F. Campbell Co. v. Commissioner Docket No. 19591. … See Rouss v. Bowers, 30 Fed.(2d) 628 .

Sonora Bank & Trust Co. v. Commissioner

7 B.T.A. 66 · United States Board of Tax Appeals · May 25, 1927

SONORA BANK & TRUST CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sonora Bank & Trust Co. v. Commissioner Docket No. 7838. … United States Board of Tax Appeals 7 B.T.A. 66 ; 1927 BTA LEXIS 3261 ; May 25, 1927 , Promulgated *3261 1.

Green v. Commissioner

27 B.T.A. 1195 · United States Board of Tax Appeals · Apr 14, 1933

In support of its contention that it comes within the purview of the net loss section petitioner cites many decisions of this Board. In one, O. A. Refling, Executor, 17 B. T. … See Flint v. Stone Tracy Co., 220 U. S. 107 ; Hughes v. Commissioner, 38 Fed. (2d) 755. And in J. J. Harrington, 1 B. T.

Luce v. Commissioner

18 B.T.A. 923 · United States Board of Tax Appeals · Jan 27, 1930

Until he received income her rights were “ upon the contract and not in remP Mitchell v. Bowers, 15 Fed. (2d) 287. See also J. V. Leydig, 15 B. T. A. 124, and Bing v. Bowers, 22 Fed. (2d) 450; aff'd., 26 Fed. (2d) 1017. … The petitioners cite and rely on a number of decisions, both by the courts and the Board, among which are O'Malley Keyes v. Eaton, 24 Fed. (2d) 436; Young v. Gnichtel, 28 Fed. (2d) 789; C. R. Thomas, 8 B. T.

First Nat'l Bank v. Commissioner

12 B.T.A. 1387 · United States Board of Tax Appeals · Jul 17, 1928

FIRST NATIONAL BANK, PARKERS LANDING, PA., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. First Nat'l Bank v. Commissioner Docket No. 14571. … United States Board of Tax Appeals 12 B.T.A. 1387 ; 1928 BTA LEXIS 3349 ; July 17, 1928 , Promulgated *3349 1.

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.

Smith Ins. Service, Inc. v. Commissioner

9 B.T.A. 284 · United States Board of Tax Appeals · Nov 23, 1927

SMITH INSURANCE SERVICE, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Smith Ins. Service, Inc. v. Commissioner Docket No. 10901. … Reviewed by the Board. Judgment will be entered on 15 days' notice, under Rule 50.

Winder Nat'l Bank v. Commissioner

16 B.T.A. 12 · United States Board of Tax Appeals · Apr 15, 1929

WINDER NATIONAL BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Winder Nat'l Bank v. Commissioner Docket No. 25199. … Reviewed by the Board. Judgment will be entered for the respondent.

Walsh v. Commissioner

7 B.T.A. 1104 · United States Board of Tax Appeals · Aug 22, 1927

WALSH, EXECUTOR, ESTATE OF RICHARD PINHORN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Walsh v. Commissioner Docket No. 6388. … United States Board of Tax Appeals 7 B.T.A. 1104 ; 1927 BTA LEXIS 3012 ; August 22, 1927 , Promulgated *3012 Value of property for estate-tax purposes determined. Joseph J. Walsh, Esq., pro se. A. G.

Oakland Bank v. Commissioner

23 B.T.A. 256 · United States Board of Tax Appeals · May 15, 1931

Civil Code of California, sec. 164; Fanning v. Green, 104 Pac. 308 . See also Miller v. Brode, 199 Pac. 531 . The form of the conveyance is itself some evidence of an intent to make such a gift. Shaw v. … Reviewed by the Board. Judgment will be entered under Rule 50. MoRRis, Sternhagen, Murdock, and McMahok dissent.

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.”

Wood v. Commissioner

27 B.T.A. 162 · United States Board of Tax Appeals · Nov 29, 1932

Petitioner, relying mainly upon Chattanooga Savings Bank v. Brewer, 9 Fed. (2d) 982; affd., 17 Fed. (2d) 79; certiorari denied, 274 U. S. 751 ; and Hadley v. Commissioner, 36 Fed. (2d) 543; affirming 6 B. T. … Hellmich v. Hellman, 276 U. S. 233 . Reviewed by the Board. Judgment will be entered vmider Bule 50.