Case law

Dallas Title & Guaranty Co. v. Commissioner

40 B.T.A. 1022 · United States Board of Tax Appeals · Dec 6, 1939

Bowers v. Lawyers’ Mortgage Co., 285 U. S. 182 ; Lincoln Mortgage & Title Guaranty Co. v. Commissioner, 79 Fed. (2d) 585; Empire Title & Guarantee Co. v. United States, 101 Fed. (2d) 69. … United States v. Scott & Sons, Inc., 69 Fed. (2d) 728. Estate of William Steele, 34 B. T. A. 173, and cases there cited. On the issue of estoppel we hold in favor of the petitioner. Reviewed by the Board.

Ben Ginsburg Co. v. Commissioner

19 B.T.A. 81 · United States Board of Tax Appeals · Feb 27, 1930

BEN GINSBURG CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Ben Ginsburg Co. v. Commissioner Docket No. 45556. … United States Board of Tax Appeals 19 B.T.A. 81 ; 1930 BTA LEXIS 2470 ; February 27, 1930 , Promulgated *2470 Affiliated corporations filing a consolidated return under the provisions of the Revenue Act of 1926 are entitled

Columbus Canning Co. v. Commissioner

10 B.T.A. 1085 · United States Board of Tax Appeals · Feb 29, 1928

Whitewater Tile & Pressed Brick Co. v. Baker, 142 Wis. 420 ; 125 N. W. 984 ; Knutson Hardware Co., 5 B. T. A. 9. … Reviewed by the Board. Decision will be entered on W days’ notice, under Rule 50. MuRdock concurs in the result.

Schneider v. Commissioner

35 B.T.A. 183 · United States Board of Tax Appeals · Dec 17, 1936

Helvering v. St. Louis Union Trust Co., 296 U. S. 39 . … Reviewed by the Board. Judgment will be entered under Bule 50.

Melick v. Commissioner

6 B.T.A. 70 · United States Board of Tax Appeals · Feb 7, 1927

MELICK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Melick v. Commissioner Docket No. 7623. … United States Board of Tax Appeals 6 B.T.A. 70 ; 1927 BTA LEXIS 3603 ; February 7, 1927 , Promulgated *3603 The stock in a bank owned by the petitioner was worthless at the end of 1921 and the cost thereof was a proper deduction

Sullivan Granite Constr. Co. v. Commissioner

6 B.T.A. 703 · United States Board of Tax Appeals · Apr 2, 1927

SULLIVAN GRANITE CONSTRUCTION CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sullivan Granite Constr. Co. v. Commissioner Docket No. 8790. … United States Board of Tax Appeals 6 B.T.A. 703 ; 1927 BTA LEXIS 3437 ; April 2, 1927 , Promulgated *3437 Samuel Freedman, C.P.A., for the petitioner. C. H. Curl, Esq., for the respondent.

Smith v. Commissioner

45 B.T.A. 948 · United States Board of Tax Appeals · Dec 9, 1941

Paine); or where the beneficiaries had no more than contingent interests, dependent upon the trustee’s discretion (Helvering v. Blair and Commissioner v. Taylor). … The court remanded the proceeding to the Board “on the issue whether the beneficiaries took future interests in property.”

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.

Selwyn Eddy Co. v. Commissioner

25 B.T.A. 1341 · United States Board of Tax Appeals · Apr 29, 1932

SELWYN EDDY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Selwyn Eddy Co. v. Commissioner Docket No. 21612. … and the date of final decision by said Board.

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.

Stange-Elliott Coal Co. v. Commissioner

4 B.T.A. 745 · United States Board of Tax Appeals · Aug 4, 1926

Stange-Elliott Coal Co. v. Commissioner Docket No. 5745. United States Board of Tax Appeals 4 B.T.A. 745 ; 1926 BTA LEXIS 2219 ; August 4, 1926 , Decided *2219 1. … The Board is without jurisdiction to redetermine overassessment for a year in which no deficiency has been asserted. 2.

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.

Law & Credit Co. v. Commissioner

5 B.T.A. 57 · United States Board of Tax Appeals · Oct 13, 1926

Law & Credit Co. v. Commissioner Docket No. 508. United States Board of Tax Appeals 5 B.T.A. 57 ; 1926 BTA LEXIS 1990 ; October 13, 1926 . Decided *1990 1. … LANSDON: The only questions remaining for the Board to determine are as to the salaries allowable under the law to Ernest E. and Elbert E.

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.

Stein v. Commissioner

9 B.T.A. 486 · United States Board of Tax Appeals · Dec 6, 1927

American Net & Twine Co. v. Worthington, 141 U. S. 468, 474 ; Benziger v. United States, 192 U. S. 38, 55; Gould v. Gould, 245 U. S. 151 . … Shwab v. Doyle, 269 Fed. 321 ; Rea v.

Rosenbaum Bros., Inc. v. Commissioner

11 B.T.A. 736 · United States Board of Tax Appeals · Apr 20, 1928

ROSENBAUM BROTHERS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Rosenbaum Bros., Inc. v. Commissioner Docket No. 13050. … . *740 This Board has several times been called upon to pass upon similar questions.

Neville v. Commissioner

29 B.T.A. 450 · United States Board of Tax Appeals · Nov 24, 1933

In Howbert v. Penrose, 38 Fed. (2d) 577, the court quoted with approval from Towne v. … De Ganay v. Lederer, 250 U.S. 376 , 39 S.Ct. 524 , 63 L.Ed. 1042; Cummings v. Clark, 2 F. (2d) 442 (C.C.A. 3) ; Towne v. McElligott, supra. The decision of the Supreme Court in De Ganay v.

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.

Bliss v. Commissioner

26 B.T.A. 731 · United States Board of Tax Appeals · Jul 27, 1932

VALENTINE BLISS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Bliss v. Commissioner Docket No. 53422. … The respondent cites no authority either of the Board or the courts *1272 to support his contention.

Ekdahl v. Commissioner

18 B.T.A. 1230 · United States Board of Tax Appeals · Feb 18, 1930

HARRY EKDAHL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Ekdahl v. Commissioner Docket No. 24271. … Reviewed by the Board. Decision will be entered for the petitioner. MARQUETTE dissents.