Case law

Bankers Trust Co. v. Commissioner

24 B.T.A. 10 · United States Board of Tax Appeals · Sep 11, 1931

By amendment to its petition and by motion to dismiss petitioner challenges the jurisdiction of the Board, objecting to the misnomer in the deficiency notice and asserting that, because of his failure to address said notice … Respondent relies upon the decision in May v. Heiner, 281 U. S. 238 .

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.

Sacks v. Commissioner

25 B.T.A. 415 · United States Board of Tax Appeals · Jan 29, 1932

SACKS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sacks v. Commissioner Docket No. 39851. … Chapin and Sacks Manufacturing Company was succeeded by Chapin-Sacks Corporation in 1920 and petitioner became vice president and chairman of the board of the company in charge of its finances.

Hammerschmidt & Frazen Co. v. Commissioner

12 B.T.A. 811 · United States Board of Tax Appeals · Jun 25, 1928

HAMMERSCHMIDT & FRANZEN CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Hammerschmidt & Frazen Co. v. Commissioner Docket No. 13751. … Bunge were the officers of the corporation and constituted its board of directors.

Transcalifornia Oil Co. v. Commissioner

37 B.T.A. 119 · United States Board of Tax Appeals · Jan 20, 1938

TRANSCALIFORNIA OIL COMPANY, LIMITED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Transcalifornia Oil Co. v. Commissioner Docket No. 73111. … Those three officers constituted the board of directors of the new corporation.

C. Niss & Sons, Inc. v. Commissioner

22 B.T.A. 732 · United States Board of Tax Appeals · Mar 13, 1931

NISS & SONS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. C. Niss & Sons, Inc. v. Commissioner Docket No. 47089. … United States Board of Tax Appeals 22 B.T.A. 732 ; 1931 BTA LEXIS 2077 ; March 13, 1931 , Promulgated *2077 Where petitioner, at the beginning of the year 1927, elected to report income on the installment basis instead of

Hutchins Lumber & Storage Co. v. Commissioner

4 B.T.A. 705 · United States Board of Tax Appeals · Aug 3, 1926

Hutchins Lumber & Storage Co. v. Commissioner Docket No. 3307. United States Board of Tax Appeals 4 B.T.A. 705 ; 1926 BTA LEXIS 2221 ; August 3, 1926 , Decided *2221 1. … The only other items, the value of which the Board is called upon to determine, are the land with its improvements and the lumber.

Pinellas Ice & Cold Storage Co. v. Commissioner

21 B.T.A. 425 · United States Board of Tax Appeals · Nov 24, 1930

Lyman v. United States Bank, 12 How. 225 ; Peter v. Beverly, 10 Pet. 532 ; United States Bank v. Daniel, 12 Pet. 32 ; King v. McConnell, 57 Fla. 77 ; 49 So. 539 ; Our Home Life Ins. Co. v. … discuss or to decide whether there was a reorganization, whether the petitioner here was a party to the reorganization, or whether the petitioner made a distribution in pursuance to a plan of reorganization. • Reviewed by the Board

Keen v. Commissioner

15 B.T.A. 1243 · United States Board of Tax Appeals · Apr 3, 1929

HERBERT IDE KEEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Keen v. Commissioner Docket No. 22262. … The case of this same petitioner was before the Board for the year 1921 in Herbert Ide Keen, 6 B.T.A. 275 .

Amsco-Wire Products Corp. v. Commissioner

44 B.T.A. 717 · United States Board of Tax Appeals · Jun 13, 1941

The parties have stipulated that the petitioner is liable as transferee for such deficiencies as the Board may finally determine, and the only question for decision is whether the can *718 cellation by the vice president … We think it clear that Helvering v. Jane Holding Corporation, supra; Beacon Auto Stores, Inc., supra; and Howard Paper Co., 43 B. T.

Partee v. Commissioner

37 B.T.A. 1112 · United States Board of Tax Appeals · Jun 24, 1938

That is the period before the Board. … Reviewed by the Board. Decision will be entered for the respondent. Hum concurs only in the result.

Recherches Industrielles, S. A. R. I. S. A. v. Commissioner

45 B.T.A. 253 · United States Board of Tax Appeals · Sep 30, 1941

RECHERCHES INDUSTRIELLS, S.A., R.I.S.A., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Recherches Industrielles, S. A. R. I. S. A. v. Commissioner Docket No. 101863. … On September 25, 1936, its board of directors appointed Farquhar J.

International Educational Publishing Co. v. Commissioner

30 B.T.A. 1090 · United States Board of Tax Appeals · Jun 29, 1934

It is true, of course, that a loss may become complete enough for deduction without the taxpayer’s establishing that there is no possibility for eventual recoupment, Wheeling Tile Co. v. … Reviewed by the Board. Decision will be entered for the respondent. Tkammell dissents.

Ewald & Co. v. Commissioner

18 B.T.A. 1130 · United States Board of Tax Appeals · Feb 13, 1930

EWALD & CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Ewald & Co. v. Commissioner Docket No. 34226. … United States Board of Tax Appeals 18 B.T.A. 1130 ; 1930 BTA LEXIS 2520 ; February 13, 1930 , Promulgated *2520 1.

Sheppard v. Commissioner

37 B.T.A. 279 · United States Board of Tax Appeals · Feb 4, 1938

SHEPPARD, TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sheppard v. Commissioner Docket No. 87430. … United States Board of Tax Appeals 37 B.T.A. 279 ; 1938 BTA LEXIS 1058 ; February 4, 1938 , Promulgated *1058 1.

Taylor v. Commissioner

14 B.T.A. 863 · United States Board of Tax Appeals · Dec 20, 1928

TAYLOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. INTERNATIONAL BEDDING CO., ASSOCIATED BUILDING CO., AND DIAMOND PILLOW, FEATHER & DOWN CO., PETITIONERS, v. … Taylor v. Commissioner Dockets Nos. 12732, 12733. United States Board of Tax Appeals 14 B.T.A. 863 ; 1928 BTA LEXIS 2897 ; December 20, 1928 , Promulgated *2897 Corporations A, B and C were affiliated.

Petroleum Exploration v. Commissioner

23 B.T.A. 890 · United States Board of Tax Appeals · Jun 29, 1931

PETROLEUM EXPLORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Petroleum Exploration v. Commissioner Docket Nos. 43480, 49339. … United States Board of Tax Appeals 23 B.T.A. 890 ; 1931 BTA LEXIS 1800 ; June 29, 1931 , Promulgated *1800 DEDUCTION - DEPRECIATION. - Amounts expended by petitioner during 1925, 1926 and 1927, representing cost of drilling

American Lace Mfg. Co. v. Commissioner

8 B.T.A. 419 · United States Board of Tax Appeals · Oct 1, 1927

AMERICAN LACE MANUFACTURING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. American Lace Mfg. Co. v. Commissioner Docket No. 8293. … United States Board of Tax Appeals 8 B.T.A. 419 ; 1927 BTA LEXIS 2884 ; October 1, 1927 , Promulgated *2884 Petitioner's invoices to customers within the United States all contain as a statement of terms of sale the phrase

Carstairs v. Commissioner

20 B.T.A. 298 · United States Board of Tax Appeals · Jul 22, 1930

JAMES CARSTAIRS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Carstairs v. Commissioner Docket No. 34513. … United States Board of Tax Appeals 20 B.T.A. 298 ; 1930 BTA LEXIS 2156 ; July 22, 1930 , Promulgated *2156 Prior to 1922 the petitioner acquired a membership in the New York Stock Exchange for which he paid $76,000.

National Bank of South Carolina v. Commissioner

10 B.T.A. 642 · United States Board of Tax Appeals · Feb 10, 1928

NATIONAL BANK OF SOUTH CAROLINA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. National Bank of South Carolina v. Commissioner Docket No. 8628. … United States Board of Tax Appeals 10 B.T.A. 642 ; 1928 BTA LEXIS 4060 ; February 10, 1928 , Promulgated *4060 1.