Case law

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.

Citron-Byer Co. v. Commissioner

21 B.T.A. 308 · United States Board of Tax Appeals · Nov 12, 1930

CITRON-BYER CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Citron-Byer Co. v. Commissioner Docket No. 37853. … It is agreed that in the event the Board decides in favor of the petitioner the amount of the deficiency or overpayment may be settled under Rule 50. 3.

Staff v. Commissioner

29 B.T.A. 121 · United States Board of Tax Appeals · Oct 17, 1933

STAFF, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. CHARLES STAFF, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Staff v. Commissioner Docket Nos. 55601, 55602. … United States Board of Tax Appeals 29 B.T.A. 121 ; 1933 BTA LEXIS 995 ; October 17, 1933 , Promulgated *995 J. H. Amick, C.P.A., for the petitioner. Milford H. Payne, Esq., for the respondent. MCMAHON *121 OPINION.

JEFERSON v. COMMISSIONER

40 B.T.A. 274 · United States Board of Tax Appeals · Jul 25, 1939

JEFERSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JEFERSON v. COMMISSIONER Docket No. 93586. … The analogy is not apparent to the Board. The respondent contends that the deduction is expressly denied by section 24(a)(4).

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.

General Utilities & Operating Co. v. Commissioner

27 B.T.A. 1200 · United States Board of Tax Appeals · Apr 24, 1933

We held: The petitioner, by resolution of its board of directors, of October 17, 1922, only incurred an obligation to distribute the 9,000 shares of Amalgamated Sugar Co. stock to its stockholders, which obligation it fully … In State v. B. & O. R.

Long v. Commissioner

1 B.T.A. 796 · United States Board of Tax Appeals · Mar 17, 1925

Long v. Commissioner Docket No. 409. … From the evidence introduced at the hearing the Board makes the following FINDINGS OF FACT.

Chicago Insulated Wire & Mfg. Co. v. Commissioner

10 B.T.A. 1195 · United States Board of Tax Appeals · Mar 7, 1928

CHICAGO INSULATED WIRE & MANUFACTURING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Chicago Insulated Wire & Mfg. Co. v. Commissioner Docket No. 2380. … On March 7, 1925, petitioner filed its petition with this Board. OPINION. LITTLETON: The written consent entered into between petitioner and the Commissioner expired April 1, 1924.

Sioux City Stock Yards Co. v. Commissioner

21 B.T.A. 973 · United States Board of Tax Appeals · Dec 30, 1930

Dry Goods Co. v. United States, 280 U. S. 453 . … Gauley Mountain Coal Co. v. Commissioner, 23 Fed. (2d) 574.

Jackman v. Commissioner

44 B.T.A. 704 · United States Board of Tax Appeals · Jun 11, 1941

State v. Hubbard, 126 Kans. 129 ; 266 Pac. 939 . … Eeviewed by the Board. Decision will be entered for the petitioner.

Omaha Nat'l Bank v. Commissioner

29 B.T.A. 817 · United States Board of Tax Appeals · Jan 18, 1934

Burnet v. Logan, 283 U.S. 404 . The promise in this case — to deliver stock — was not unconditional. Something remained to be done before the employee could draw down the stock. … Reviewed by the Board. Decision will be entered for the respondent.

Dinkler v. Commissioner

22 B.T.A. 329 · United States Board of Tax Appeals · Feb 24, 1931

See Thronateeska Pecal Co. v. Matthews, 277 Fed. 361 ; Meyer v. Ritter, 268 Fed. 937 . … Reviewed by the Board. Judgment mil be entered under Rule 50.

Champion Coated Paper Co. v. Commissioner

10 B.T.A. 433 · United States Board of Tax Appeals · Feb 1, 1928

Provision is made for the approval by the court of the appraisals made of benefits, and the board of directors is thereupon empowered to levy assessments upon the real property not in excess of the appraised benefits to such … In the case of Miami County v. Dayton, 92 Ohio State 215 ; 110 N.

Harry S. Kaufman, Ltd. v. Commissioner

2 B.T.A. 177 · United States Board of Tax Appeals · Jun 26, 1925

Kaufman, Ltd. v. Commissioner Docket No. 1206. … From the oral and documentary evidence, and the allegations of the petition admitted by the Commissioner, the Board makes the following FINDINGS OF FACT. 1.

Union Land Co. v. Commissioner

16 B.T.A. 2 · United States Board of Tax Appeals · Apr 15, 1929

ELLIS LUMBER CO., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Union Land Co. v. Commissioner Docket No. 16428. … The petitioners claim that the above decision of the Board is not controlling for the reason that in that appeal the Board did not have before it all of the material facts which are set forth in the stipulation in the present

Reed v. Commissioner

13 B.T.A. 513 · United States Board of Tax Appeals · Sep 25, 1928

The record does not reveal to what extent, if at all, their services wre subject to the direction or control of the public boards or officers engaging them. … Reviewed by the Board. Judgment will be entered for the respondent. Geeen, Milliken, Van Fossan, and Siefkin dissent on the first point.

Wells v. Commissioner

29 B.T.A. 222 · United States Board of Tax Appeals · Oct 31, 1933

WELLS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Wells v. Commissioner Docket No. 62948. … Reviewed by the Board. Judgment will be entered for the petitioner. SEAWELL and ADAMS dissent. Footnotes 1.

Polachek v. Commissioner

3 B.T.A. 1051 · United States Board of Tax Appeals · Mar 30, 1926

Polachek v. Commissioner Docket No. 828. … Order will be entered accordingly. *1055 On reference to the Board, STERNHAGEN and LOVE dissent. PHILLIPS, dissenting: I can not agree with the conclusion which has been reached.

Kaufman v. Commissioner

9 B.T.A. 1180 · United States Board of Tax Appeals · Jan 12, 1928

KAUFMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. MRS. E. R. KAUFMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Kaufman v. Commissioner Docket Nos. 12811, 12812. … Reviewed by the BOARD. Judgment will be entered for the petitioners on 15 days' notice, under Rule 50.

Lehigh & Hudson River Railway Co. v. Commissioner

13 B.T.A. 1154 · United States Board of Tax Appeals · Oct 19, 1928

See also Consolidated Tea Co. v. Bowers, 19 Fed. (2d) 382. … Reviewed by the Board. Judgment will he entered wider Rule 50. Phillips, GkeeN, MillikeN, and Van FossaN dissent.