Case law

Brown v. Commissioner

1 B.T.A. 201 · United States Board of Tax Appeals · Dec 18, 1924

Appeal of PAUL BROWN. Brown v. Commissioner Docket No. 252. United States Board of Tax Appeals 1 B.T.A. 201 ; 1924 BTA LEXIS 215 ; December 18, 1924 , decided Submitted December 3, 1924 . *215 Mr. … Paul Brown, the taxpayer, in pro. per. W. Frank Gibbs, Esq. (Nelson T. Hartson, Solicitor of Internal Revenue) for the Commissioner. *201 Before IVINS, KORNER, and MARQUETTE. FINDINGS OF FACT.

Brown v. Commissioner

9 B.T.A. 965 · United States Board of Tax Appeals · Dec 28, 1927

BROWN AND OTTO J. THOMEN. Brown v. Commissioner Docket Nos. 3110, 3364. United States Board of Tax Appeals 9 B.T.A. 965 ; 1927 BTA LEXIS 2484 ; December 28, 1927 , Promulgated *2484 1. … See also Kerbaugh-Empire Co. v. Bowers, 271 U.S. 170 ; Appeal of Independent Brewing Co., 4 B.T.A. 870 .

H. H. Brown Co. v. Commissioner

8 B.T.A. 112 · United States Board of Tax Appeals · Sep 19, 1927

See Sherwin v. Boston Five Cents Saving Bank, 137 Mass. 444 ; Cochran v. Guild, 106 Mass. 29, 30 ; Burr v. Wilcox, 13 Allen, 269 , 272; Wilson v. Shearer, 9 Met. 504 , 506; Sherwin v. Wigglesworth, 129 Mass. 64 . … Reviewed by the Board. Judgment will be entered on Id days’ notice, wnder Bule SO.

Brown Agency, Inc. v. Commissioner

21 B.T.A. 1111 · United States Board of Tax Appeals · Jan 12, 1931

hearing the respondent admitted that evidence adduced at the hearing, which had never been previously put before the respondent, lead unavoidably to the conclusion that the officers’ salaries were duly authorized by the board

Ennis-Brown Co. v. Commissioner

10 B.T.A. 1248 · United States Board of Tax Appeals · Mar 8, 1928

The opinion of the Board in Butler's Warehouses, Inc., 1 B. T. A., 851, contains quotations from the Congressional Record showing the intent of Congress in enacting section 204 of the Revenue Act of 1918. … Auburn & Alton Coal Co., v. United States, 61 Ct. Cls. 438. This petitioner’s fiscal year 1919 began September 1, 1918, prior to the period designated by the special relief provisions of section 204 of the 1918 Act.

Beck-Brown Realty Co. v. Commissioner

46 B.T.A. 1225 · United States Board of Tax Appeals · May 28, 1942

Brown, its president. On January 30, 1931, pursuant to the loan agreement, petitioner gave Ageloff a check for $40,000, signed by Brown and Charles F. Beck as president and treasurer of petitioner, respectively. … Dalton v. Bowers, supra.

Brown v. Commissioner

47 B.T.A. 139 · United States Board of Tax Appeals · Jun 16, 1942

The Second Circuit Court of Appeals in two cases, Seaside Improvement Co. v. Commissioner, supra, and Commissioner v. Appleby Estate, supra, and the Board in Henry A. … Burnet v. Houston, 283 U. S. 223 . Fourth Issue.

Brown Fence & Wire Co. v. Commissioner

46 B.T.A. 344 · United States Board of Tax Appeals · Feb 18, 1942

The court in United States v. Brown Fence & Wire Co., 9 Fed. … United States v. Anderson, 269 U. S. 422 ; Dougherty’s Sons, Inc. v. Commissioner, 121 Fed. (2d) 700; Commissioner v. Central United National Bank, 99 Fed. (2d) 568; Continental Baking Corporation, 30 B. T.

Brown v. Commissioner

26 B.T.A. 781 · United States Board of Tax Appeals · Aug 9, 1932

Petitioner also relies upon the decision in Burnet v. Logan, 283 U. S. 404 . … See also Commissioner v. Moore, 48 Fed. (2d) 526 (certiorari denied) ; Commissioner v. Garber, 50 Fed. (2d) 588.

Brown v. Commissioner

38 B.T.A. 298 · United States Board of Tax Appeals · Aug 10, 1938

This case and the case of Helvering v. Grinnell, 294 U. … Stratton v. United States, 50 Fed. (2d) 48, decided by the Circuit Court of Appeals for the First Circuit some four years prior to the decision of Helvering v. Grinnell, supra, is squarely in point.

Clark Brown Grain Co. v. Commissioner

18 B.T.A. 937 · United States Board of Tax Appeals · Jan 29, 1930

Greylock Mills v. Blair, 293 Fed. 846 . … Ennis-Brown Co., 10 B. T. A. 1248.

Rogers, Brown & Crocker Bros., Inc. v. Commissioner

32 B.T.A. 307 · United States Board of Tax Appeals · Mar 29, 1935

Brown ex rel. Mitchell v. Commissioner

5 B.T.A. 209 · United States Board of Tax Appeals · Oct 27, 1926

Brown, is entitled to a deduction in 1918 or 1919 with respect to advances made to the Ajax Co., and whether he is entitled to a loss with respect to his investment in the stock of that company. … There is no evidence that Brown exercised bad judgment in his control of the corporation in acquiring the properties which the corporation operated.

De Brown Auto Sales Co. v. Commissioner

2 B.T.A. 896 · United States Board of Tax Appeals · Oct 16, 1925

You may state who kept the minutes of the meeting of the Board of Directors on January 6, 1919. A. I did. Q. What directors were present at that meeting? A. L. H. DeBrown, W. E. Barkley, Frank DeBrown, C. F.

Manchester Board & Paper Co. v. Commissioner

29 B.T.A. 108 · United States Board of Tax Appeals · Oct 12, 1933

Bonwit Teller & Co. v. Commissioner., 53 Fed. (2d) 381, certiorari denied, 284 U.S. 690 . We do not know that these privileges had any value. … Bonwit Teller & Co. v. Commissioner, supra; 353 Lexington Ave. Corp., 27 B.T.A. 762 ; sec. 111 (b) (2), Revenue Act of 1928.

W. P. Brown & Sons Lumber Co. v. Commissioner

26 B.T.A. 1192 · United States Board of Tax Appeals · Oct 12, 1932

Apparently the Brown Realty Company was incorporated in the fall of 1922. … Commissioner, 43 Fed. (2d) 331, and Frank & Seder Co. v. Commissioner, 44 Fed. (2d) 147. These two cases reversed Board decisions reported at 15 B.T.A. 881 , and 13 B.T.A. 1 , respectively.

Board of Fire Underwriters v. Commissioner

26 B.T.A. 860 · United States Board of Tax Appeals · Aug 17, 1932

Its only receipts came by requisition from the National Board of Fire Underwriters and any excess' of receipts over disbursements was deducted in arriving at future estimates. … Eisner v. Maeomiber, 252 U. S. 189 .

R. L. Brown Coal & Coke Co. v. Commissioner

14 B.T.A. 609 · United States Board of Tax Appeals · Dec 7, 1928

Brown, as an individual, received a liquidating dividend from R. L. Brown Coal & *615 Coke Co. in 1921 of $29,425.38. … Brown as an individual and not to the company. The evidence indicates that R. L. Brown received no liquidating dividend from the corporation in 1921. The contention of the petitioners upon this point is sustained.

Schumacher Wall Board Corp. v. Commissioner

33 B.T.A. 1211 · United States Board of Tax Appeals · Feb 26, 1936

Three of the Schumacher individuals also owned a group of patents relating to the manufacture of wall board. … We there held, citing West Texas Refining & Development Co. v. Commissioner, 68 Fed. (2d) 77, that the new corporation was not limited to the basis of the old, but was entitled to use cost as the basis.

R. L. Brown Coal & Coke Co. v. Commissioner

14 B.T.A. 609 · United States Board of Tax Appeals · Dec 7, 1928

Brown, as an individual, received a liquidating dividend from R. L. Brown Coal & *615 Coke Co. in 1921 of $29,425.38. … Brown as an individual and not to the company. The evidence indicates that R. L. Brown received no liquidating dividend from the corporation in 1921. The contention of the petitioners upon this point is sustained.