Case law

Lafayette Lumber Co. v. Commissioner

20 B.T.A. 993 · United States Board of Tax Appeals · Sep 25, 1930

This Board has always held that bad debts may not be deducted as losses under subsection (4). See Emil Stern et al., 5 B. T. A. 89; First National Bank of St. Paul, 10 B. T. … In Lewellyn v.

Waggoner v. Commissioner

5 B.T.A. 1191 · United States Board of Tax Appeals · Jan 26, 1927

United States v. Anderson, 269 U. S. 422 ; United States v. Mitchell, 271 U. S. 9 ; Appeal of Consolidated Asphalt Co., 1 B. T. A. 79; Appeal of Henry Reubel, 1 B. T. A. 676. Royalties are income. Sargent Land Co. v. … S. 503 ; Alworth-Stephens Co. v. Lynch, 278 Fed. 959 ; 294 Fed. 190 ; 267 U. S. 364 .

Winthrop v. Commissioner

36 B.T.A. 314 · United States Board of Tax Appeals · Jul 13, 1937

In United States v. White Dental Manufacturing Co., 274 U. … Reviewed by the Board. Judgment will be entered under Rule 50.

H. P. Robertson Co. v. Commissioner

14 B.T.A. 887 · United States Board of Tax Appeals · Dec 21, 1928

municipality where recovery is not always easy, it would indeed require a high degree of optimism to say, at the close of 1920, that the loss suffered would be compensated for, and as Justice Stone said in United States v. … A. 759, and United States v. White Dental Manufacturing Co. of Pennsylvania, supra. Reviewed by the Board. Judgment will be entered under Rule 50. Sternhagen and Moeeis concur in the result.

Tobin v. Commissioner

17 B.T.A. 1261 · United States Board of Tax Appeals · Nov 6, 1929

TOBIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Tobin v. Commissioner Docket No. 25922. … United States Board of Tax Appeals 17 B.T.A. 1261 ; 1929 BTA LEXIS 2158 ; November 6, 1929 , Promulgated *2158 The compensation received by the petitioner during the year 1923 as counsel of the New York State Commission to

Duriron Co. v. Commissioner

18 B.T.A. 554 · United States Board of Tax Appeals · Dec 20, 1929

THE DURIRON CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Duriron Co. v. Commissioner Docket No. 23930. … United States Board of Tax Appeals 18 B.T.A. 554 ; 1929 BTA LEXIS 2020 ; December 20, 1929 , Promulgated *2020 Petitioner reported its income on the basis of a calendar year.

Estate of Field v. Commissioner

45 B.T.A. 270 · United States Board of Tax Appeals · Oct 7, 1941

The problem is similar to that involved in Ithaca Trust Co. v. United States, 279 U. S. 151. … Reviewed by the Board. Decision will be entered under Rule SO. Black, Turner, Kern, and Opper dissent. Income was about five times the amount needed for the annuities in the Bonflls case.

Clark v. Commissioner

2 B.T.A. 555 · United States Board of Tax Appeals · Sep 9, 1925

Clark v. Commissioner Docket No. 1707. … From the evidence submitted by depositions and exhibits the Board makes the following FINDINGS OF FACT.

Chicago Warehouse Lumber Co. v. Commissioner

16 B.T.A. 1416 · United States Board of Tax Appeals · Jul 24, 1929

CHICAGO WAREHOUSE LUMBER CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Chicago Warehouse Lumber Co. v. Commissioner Docket No. 21427. … United States Board of Tax Appeals 16 B.T.A. 1416 ; 1929 BTA LEXIS 2386 ; July 24, 1929 , Promulgated *2386 A cancellation of stockholders' and officers' indebtedness tentatively agreed to in 1922 but as to which formal action

Stifel v. Commissioner

7 B.T.A. 1060 · United States Board of Tax Appeals · Aug 9, 1927

STIFFL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Stifel v. Commissioner Docket No. 6470. … United States Board of Tax Appeals 7 B.T.A. 1060 ; 1927 BTA LEXIS 3033 ; August 9, 1927 , Promulgated *3033 Debts, not ascertained to be worthless and charged off as such on decedent's books during the taxable period, can

Acme Mills, Inc. v. Commissioner

6 B.T.A. 1065 · United States Board of Tax Appeals · Apr 26, 1927

ACME MILLS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Acme Mills, Inc. v. Commissioner Docket No., 1598. … , the selling price does not establish the March 1, 1913, market value thereof, since there was not the open market and freedom from compulsion in that sale that is contemplated by the Board's prior rulings.

Turrish v. Commissioner

24 B.T.A. 913 · United States Board of Tax Appeals · Nov 25, 1931

HENRY TURRISH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Turrish v. Commissioner Docket No. 44742. … Timber and lumber operations have been his vocation and this is the test very early applied by the Board. *1571 .

O'Bryan Bros. v. Commissioner

42 B.T.A. 18 · United States Board of Tax Appeals · Jun 11, 1940

Kennedy, Sr., remained as chairman of the board of directors but confined his activities to selling. … In support of this contention respondent relies on the case of Hill Co. v. Commissioner, 64 Fed. (2d) 506; certiorari denied, 290 U. S. 691 , affirming 22 B. T.

Rockwood Sprinkler Co. v. Commissioner

13 B.T.A. 393 · United States Board of Tax Appeals · Sep 19, 1928

COMMISSIONER OF INTERNAL REVENUE, RESPONDENT., PETITIONER, v. Rockwood Sprinkler Co. v. Commissioner Docket No. 14937. … Reviewed by the Board. Decision will be entered for the respondent.

Aranow v. Commissioner

38 B.T.A. 1089 · United States Board of Tax Appeals · Nov 4, 1938

Petitioner insists that in the instant case, in view of the fact that the law at the time of the filing of the taxpayer’s return was expressed by the decisions of this Board in the cases of David K. Cochrane, 26 B. T. … In the case of Saxe v.

Allhands v. Commissioner

10 B.T.A. 1089 · United States Board of Tax Appeals · Feb 29, 1928

ALLHANDS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Allhands v. Commissioner Docket No. 10284. … Reviewed by the Board. Judgment will be entered for the respondent. STERNHAGEN, PHILLIPS, and MURDOCK concur in the result. TRUSSELL dissents.

Watson v. Commissioner

42 B.T.A. 52 · United States Board of Tax Appeals · Jun 13, 1940

WATSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Watson v. Commissioner Docket Nos. 87873, 88048, 89650. … Burnet v. Commonwealth Improvement Co., 287 U.S. 415 , and Higgins v. Smith, 308 U.S. 473 , followed. 3.

Dunning v. Commissioner

36 B.T.A. 1222 · United States Board of Tax Appeals · Dec 31, 1937

See Reinecke v. Northern Trust Co., 278 U. S. 839 , 341; Becker v. St. Louis Union Trust Co., 296 U. S. 48, 49 . … The opinion in Burnet v.

State Bank of Springfield v. Commissioner

11 B.T.A. 410 · United States Board of Tax Appeals · Apr 3, 1928

STATE BANK OF SPRINGFIELD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. State Bank of Springfield v. Commissioner Docket No. 11149. … United States Board of Tax Appeals 11 B.T.A. 410 ; 1928 BTA LEXIS 3819 ; April 3, 1928 , Promulgated *3819 E. L. Nippolt for the petitioner. J. Harry Byrne, Esq., for the respondent.

Farmers' Union Co-Op. Ass'n v. Commissioner

13 B.T.A. 969 · United States Board of Tax Appeals · Oct 12, 1928

FARMERS' UNION CO-OPERATIVE ASSOCIATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Farmers' Union Co-Op. Ass'n v. Commissioner Docket No. 11055. … United States Board of Tax Appeals 13 B.T.A. 969 ; 1928 BTA LEXIS 3131 ; October 12, 1928 , Promulgated *3131 Patronage dividends due members of a cooperative business association held to be part of cost of goods sold.