Case law

McNeill v. Commissioner

10 B.T.A. 1285 · United States Board of Tax Appeals · Mar 9, 1928

MCNEILL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. J. A. MCNEILL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. D. R. MCNEILL, PETITIONER, v. … McNeill v. Commissioner Docket Nos. 1743-1745.

Epsen v. Commissioner

44 B.T.A. 322 · United States Board of Tax Appeals · Apr 29, 1941

EPSTEN), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Epsen v. Commissioner Docket No. 97914. … V. Burkley and F. J. Burkley, 10 shares by F. G. Travis, and 5 shares by Sam Alperson.

Clemson v. Commissioner

5 B.T.A. 594 · United States Board of Tax Appeals · Nov 23, 1926

Clemson v. Commissioner Docket No. 6256. … This evidence is insufficient to warrant the Board in finding that the Commissioner's determination of value was erroneous. Judgment will be entered for the Commissioner.

St. Joseph Valley Bank v. Commissioner

15 B.T.A. 185 · United States Board of Tax Appeals · Feb 1, 1929

A. 1060, in which this Board considered what constituted a charge-off under several different methods of bookkeeping. … Petitioner relies principally upon the decision in the case of Rhode Island Hospital Trust Co. v. Commissioner, 29 Fed. (2d) 339.

Indiana Harbor Belt R.R. v. Commissioner

16 B.T.A. 279 · United States Board of Tax Appeals · Apr 30, 1929

INDIANA HARBOR BELT RAILROAD CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Indiana Harbor Belt R.R. v. Commissioner Docket Nos. 21550, 37661. … United States Board of Tax Appeals 16 B.T.A. 279 ; 1929 BTA LEXIS 2604 ; April 30, 1929 , Promulgated *2604 1.

First Nat'l Bank v. Commissioner

3 B.T.A. 807 · United States Board of Tax Appeals · Feb 17, 1926

First Nat'l Bank v. Commissioner Docket No. 2927. … United States Board of Tax Appeals 3 B.T.A. 807 ; 1926 BTA LEXIS 2551 ; February 17, 1926 , Decided Submitted October 5, 1925 . *2551 Attorney's fees and sums paid for services in transferring assets in connection with the

Benjamin Franklin Life Assurance Co. v. Commissioner

46 B.T.A. 616 · United States Board of Tax Appeals · Mar 12, 1942

Commissioner v. National Grange Mutual Liability Co., supra. The line, as we set out at the outset, is one to be drawn between a creditor and a shareholder. This is made clear in Commissioner v. … The court denied it, citing its earlier decision — Commis sioner v. O. P. P. Holding Corporation, 76 Fed. (2d) 11; and Jewel Tea Co. v. United States, 90 Fed. (2d) 451; and distinguishing Commissioner v.

Patapsco Ballast Co. v. Commissioner

1 B.T.A. 1081 · United States Board of Tax Appeals · Apr 29, 1925

Patapsco Ballast Co. v. Commissioner Docket No. 1800. … United States Board of Tax Appeals 1 B.T.A. 1081 ; 1925 BTA LEXIS 2677 ; April 29, 1925 , decided Submitted March 31, 1925 . *2677 A corporation reporting on a calendar year basis, having a fractional calendar year in 1918

Arrowhead Mills, Inc. v. Commissioner

5 B.T.A. 382 · United States Board of Tax Appeals · Nov 9, 1926

Arrowhead Mills, Inc. v. Commissioner Docket No. 3214. … On March 13, 1916, a resolution was passed by the Board of Public Works of the City of Fulton granting permission to Nelson T.

Snyder & Berman, Inc. v. Commissioner

41 B.T.A. 1180 · United States Board of Tax Appeals · May 21, 1940

SNYDER & BERMAN, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Snyder & Berman, Inc. v. Commissioner Docket Nos. 99409, 99952. … Reviewed by the Board. Decision will be entered for the respondent.

Walter W. Rose Inv. Co. v. Commissioner

24 B.T.A. 215 · United States Board of Tax Appeals · Sep 29, 1931

ROSE INVESTMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Walter W. Rose Inv. Co. v. Commissioner Docket No. 43241. … Reviewed by the Board. Judgment will be entered under Rule 50. STERNHAGEN, MURDOCK, and SEAWELL dissent.

Moser v. Commissioner

12 B.T.A. 671 · United States Board of Tax Appeals · Jun 15, 1928

MOSER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Moser v. Commissioner Docket No. 7198. … United States Board of Tax Appeals 12 B.T.A. 671 ; 1928 BTA LEXIS 3494 ; June 15, 1928 , Promulgated *3494 Commissioner's determination of an earned income credit of a partner approved. John G. Remey, Esq., and R. S.

Doric Apartment Co. v. Commissioner

32 B.T.A. 1187 · United States Board of Tax Appeals · Aug 9, 1935

Since the determination of the Commis *1191 sioner was incorrect the Board must determine, as best it can from the evidence, the total fair market value of the notes. Cf. Cohan v. … Commissioner, 39 Fed. (2d) 540; Helvering v. Taylor, 293 U. S. 507 . This has been done. The decision on this question of fact is set forth in the findings of fact above.

Phoenix Seed & Feed Co. v. Commissioner

2 B.T.A. 909 · United States Board of Tax Appeals · Oct 19, 1925

Phoenix Seed & Feed Co. v. Commissioner Docket No. 1955. … United States Board of Tax Appeals 2 B.T.A. 909 ; 1925 BTA LEXIS 2224 ; October 19, 1925 , Decided Submitted July 15, 1925 . *2224 Method of determining excess-profits tax for 1917. Lawrence H.

Houston Lighting & Power Co. v. Commissioner

34 B.T.A. 745 · United States Board of Tax Appeals · Jul 3, 1936

Storm v. United States, 94 U. S. 76 ; Chicago, etc. R. Co. v. United States, 218 Fed. 288 ; aff'd., 244 U. S. 351 . … Reviewed by the Board. Judgment will be entered for the respondent.

Nelms v. Commissioner

5 B.T.A. 845 · United States Board of Tax Appeals · Dec 17, 1926

NELMS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Nelms v. Commissioner Docket No. 6419. … United States Board of Tax Appeals 5 B.T.A. 845 ; 1926 BTA LEXIS 2756 ; December 17, 1926 , Promulgated *2756 The evidence is insufficient to show that the Commissioner's determination of the value of stock acquired by gift

Donner v. Commissioner

32 B.T.A. 364 · United States Board of Tax Appeals · Apr 16, 1935

See also Helvering v. Walbridge, 70 Fed. (2d) 683; certiorari denied, October 8, 1934. … Reviewed by the Board. Decision will Toe entered under Bule 50.

Brauer v. Commissioner

6 B.T.A. 579 · United States Board of Tax Appeals · Mar 22, 1927

It is immaterial as to what action the Commissioner took as regards the Schick-Johnson Co., for that determination by the Commissioner is not before the Board in this proceeding and that corporation and this petitioner are … In the case of Hayner v. United States, 62 Ct. Cls. 189, the court said in its opinion: It is admitted that the plaintiff received as salary .$13,195.79 and returned it as such for taxation.

Maxwell Bros. Grocery Co. v. Commissioner

2 B.T.A. 980 · United States Board of Tax Appeals · Oct 26, 1925

Grocery Co. v. Commissioner Docket No. 2953. United States Board of Tax Appeals 2 B.T.A. 980 ; 1925 BTA LEXIS 2195 ; October 26, 1925 , Decided Submitted July 11, 1925 . *2195 B. G.

Avidan v. Commissioner

38 B.T.A. 951 · United States Board of Tax Appeals · Oct 20, 1938

Helvering v. Gerhardt, 304 U. … Reviewed by the Board. Decision will be entered wider Rule 50. Opper concurs only in the result.