Case law

Cosmopolitan Bond & Mortgage Co. v. Commissioner

30 B.T.A. 717 · United States Board of Tax Appeals · May 16, 1934

COSMOPOLITAN BOND & MORTGAGE COMPANY (FORMERLY COSMOPOLITAN REAL ESTATE COMPANY), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Cosmopolitan Bond & Mortgage Co. v. Commissioner Docket No. 44617. … United States Board of Tax Appeals 30 B.T.A. 717 ; 1934 BTA LEXIS 1277 ; May 16, 1934 , Promulgated *1277 1.

Kent Paper Co. v. Commissioner

13 B.T.A. 273 · United States Board of Tax Appeals · Aug 22, 1928

KENT PAPER CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Kent Paper Co. v. Commissioner Docket No. 14437. … United States Board of Tax Appeals 13 B.T.A. 273 ; 1928 BTA LEXIS 3282 ; August 22, 1928 , Promulgated *3282 Solomon Goodman, Esq., for the petitioner. George S. Herr, Esq., for the respondent.

W. N. Thornburgh Mfg. Co. v. Commissioner

17 B.T.A. 29 · United States Board of Tax Appeals · Jul 31, 1929

THORNBURGH MANUFACTURING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. W. N. Thornburgh Mfg. Co. v. Commissioner Docket No. 17120. … Board of Directors shall be final.

Glenmore Sec. Corp. v. Commissioner

24 B.T.A. 697 · United States Board of Tax Appeals · Nov 10, 1931

To support its theory as to the legal effect of the syndicate agreement, petitioner relies strongly upon the case of Burnet v. Logan, 283 U. S. 404 . … Reviewed by the Board. Judgment will be entered for the respondent.

Wegeforth v. Commissioner

42 B.T.A. 633 · United States Board of Tax Appeals · Aug 28, 1940

The Board decided that such activity did not constitute a trade or business and the Board’s decision was affirmed by the Ninth Circuit. See also City Bank Farmers Trust Co., Trustee, supra. … Decision will be entered v/nder Rule 50.

Associated Dental Supply Co. v. Commissioner

9 B.T.A. 1022 · United States Board of Tax Appeals · Jan 3, 1928

ASSOCIATED DENTAL SUPPLY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Associated Dental Supply Co. v. Commissioner Docket No. 5650. … The question of reasonableness of salaries paid by corporations has been frequently before the Board and no extended discussion is necessary.

Heinz v. Commissioner

28 B.T.A. 276 · United States Board of Tax Appeals · Jun 6, 1933

Commissioner, 62 Fed. (2d) 777, and Glenmore Securities Corp. v. … In Snyder v.

Hoge v. Commissioner

33 B.T.A. 718 · United States Board of Tax Appeals · Dec 13, 1935

Wolverine Petroleum, Corporation v. Commissioner, *724 75 Fed. (2d) 593, affirming Wolverine Petroleum Corporation, 29 B. T. A. 1236. … Perry v. Page (CCA 1) 67 F. (2d) 635; Hering v. Tait (CCA 4) 65 F. (2d) 703; Bankers’ Reserve Life Co. v. United States (Ct. Cl.) 42 F. (2d) 313; Aetna Life Ins. Co. v.

Weddell v. Commissioner

21 B.T.A. 411 · United States Board of Tax Appeals · Nov 24, 1930

VIRGINIA CHASE WEDDELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Weddell v. Commissioner Docket No. 19822. … Reviewed by the Board. Decision will be entered for the respondent.

Pope v. Commissioner

28 B.T.A. 1255 · United States Board of Tax Appeals · Aug 23, 1933

Mente v. Eisner, 266 Fed. 161 ; Bedell v. Commissioner, 30 Fed. (2d) 622; Washburn v. Commissioner, 51 Fed. (2d) 949. … They, together with Miller, held the important executive offices of the company and they with Miller constituted a majority of its board of directors.

Shellabarger v. Commissioner

14 B.T.A. 695 · United States Board of Tax Appeals · Dec 13, 1928

Facts similar to those here were before the court in Bing v. … Petitioner has cited O'Malley-Keyes v. Eaton, 24 Fed. (2d) 436, followed in Young v. Gnichtel, 28 Fed. (2d) 789, as being controlling. The facts there are clearly distinguishable from those here.

Oliver Finnie Co. v. Commissioner

2 B.T.A. 134 · United States Board of Tax Appeals · Jun 23, 1925

Oliver Finnie Co. v. Commissioner Docket No. 757. United States Board of Tax Appeals 2 B.T.A. 134 ; 1925 BTA LEXIS 2540 ; June 23, 1925 , Decided Submitted April 27, 1925 . *2540 1. … From the pleadings and depositions the Board makes the following FINDINGS OF FACT.

Pence v. Commissioner

9 B.T.A. 1189 · United States Board of Tax Appeals · Jan 12, 1928

PENCE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. W. G. PENCE AND MRS. W. G. PENCE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Pence v. Commissioner Docket Nos. 7106, 8408. … Not being evidence before this Board, we can not of course give any weight to the affidavits which are appended to the petitions, nor to the statements in the petitioners' brief. .

Commercial Reference Co. v. Commissioner

7 B.T.A. 384 · United States Board of Tax Appeals · Jun 17, 1927

As stated by the court in Matteson Co. v. … The Board is of the opinion that during the taxable years the capital invested by petitioner was a material income-producing factor and also that the income of petitioner can not be ascribed primarily to the activities of

Carson v. Commissioner

47 B.T.A. 163 · United States Board of Tax Appeals · Jun 23, 1942

CARSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Carson v. Commissioner Docket No. 104474. … It is common knowledge that children frequently go away from home on a visit and those whom they are visiting furnish board, lodging, and sometimes even a few new clothes.

Ewing v. Commissioner

40 B.T.A. 912 · United States Board of Tax Appeals · Nov 15, 1939

A. 493, affd., 82 Fed. (2d) 380; and Suisman v. Eaton, 15 Fed. Supp. 113, affd., 83 Fed. (2d) 1019; certiorari denied, 299 U. … Albeit in the Kenaav case the Board, not there having the question of basis to the beneficiary, refrained from ruling on that question, the logic of the opinion and the observations of the Board in mooting the question indicate

Chapin Constr. Co. v. Commissioner

3 B.T.A. 25 · United States Board of Tax Appeals · Nov 12, 1925

Co. v. Commissioner Docket No. 3200. … United States Board of Tax Appeals 3 B.T.A. 25 ; 1925 BTA LEXIS 2071 ; November 12, 1925 , Decided Submitted June 16, 1925 . *2071 A corporation engaged in the business of road and street construction contracting, keeping

Crescent Panel Co. v. Commissioner

12 B.T.A. 561 · United States Board of Tax Appeals · Jun 13, 1928

CRESCENT PANEL CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Crescent Panel Co. v. Commissioner Docket No. 10568. … United States Board of Tax Appeals 12 B.T.A. 561 ; 1928 BTA LEXIS 3508 ; June 13, 1928 , Promulgated *3508 Promissory notes executed by the five stockholders of a corporation, made payable to the corporation but held by the

Samuels v. Commissioner

6 B.T.A. 1084 · United States Board of Tax Appeals · Apr 29, 1927

Littleton: Upon the authority of United States v. Robbins, 269 U. S. 315 , and the Board’s opinion in the Appeal of D. Cerruti, 4 B. T.

Kentucky Natural Gas Corp. v. Commissioner

47 B.T.A. 330 · United States Board of Tax Appeals · Jul 16, 1942

Marlborough Investment Co. v. … In March 1931 the Fifth Circuit, in Central Real Estate Co. v. Com missioner, 47 Fed. (2d) 1036, affirmed the Board’s opinion at 17 B. T.