Case law

Isse Koch & Co. v. Commissioner

1 B.T.A. 624 · United States Board of Tax Appeals · Feb 26, 1925

Isse Koch & Co. v. Commissioner Docket No. 322. … From admissions in the pleadings, stipulations by the parties, and evidence offered at the hearings, the Board makes the following FINDINGS OF FACT. 1.

Blackford Window Glass Co. v. Commissioner

13 B.T.A. 1268 · United States Board of Tax Appeals · Oct 30, 1928

BLACKFORD WINDOW GLASS CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Blackford Window Glass Co. v. Commissioner Docket No. 3445. … The parties further agree that the Board does not have jurisdiction over the 1918 year, as an overassessment is disclosed by the deficiency letter forming the basis of this appeal. OPINION.

C. E. McNeill & Co. v. Commissioner

14 B.T.A. 738 · United States Board of Tax Appeals · Dec 14, 1928

MCNEILL & CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. C. E. McNeill & Co. v. Commissioner Docket No. 17830. … The expenses of attending out-of-town meetings of the several trade boards were likewise charged to expense.

Halle v. Commissioner

7 B.T.A. 877 · United States Board of Tax Appeals · Jul 30, 1927

HALLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Halle v. Commissioner Docket No. 4139. United States Board of Tax Appeals 7 B.T.A. 877 ; 1927 BTA LEXIS 3078 ; July 30, 1927 , Promulgated *3078 W. B.

Minneapolis Syndicate v. Commissioner

13 B.T.A. 1303 · United States Board of Tax Appeals · Oct 30, 1928

MINNEAPOLIS SYNDICATE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Minneapolis Syndicate v. Commissioner Docket No. 10163. … Reviewed by the Board. Judgment will be entered under Rule 50.

Logue Bros. & Co. v. Commissioner

9 B.T.A. 584 · United States Board of Tax Appeals · Dec 12, 1927

LOGUE BROTHERS & CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Logue Bros. & Co. v. Commissioner Docket No. 9931. … United States Board of Tax Appeals 9 B.T.A. 584 ; 1927 BTA LEXIS 2561 ; December 12, 1927 , Promulgated *2561 The evidence fails to establish that petitioner is entitled to classification as a personal service corporation

Block v. Commissioner

41 B.T.A. 830 · United States Board of Tax Appeals · Apr 12, 1940

The petitioner cites Wyeth v. Crane, 342 Ill. 545 , and McKibben v. Pioneer Trust & Savings Bank, 365 Ill. 369 , for the proposition that *832 under the trust instrument Joseph L. Block, Leigh B. Block, Babette R. … The parties have stipulated the amount of the deficiency in the event the Board should reach the conclusion stated above. Decision will be entered in accordance with the stipulation.

Shipowners & Merchants Tugboat Co. v. Commissioner

4 B.T.A. 403 · United States Board of Tax Appeals · Jul 27, 1926

Shipowners & Merchants Tugboat Co. v. Commissioner Docket No. 3955. United States Board of Tax Appeals 4 B.T.A. 403 ; 1926 BTA LEXIS 2286 ; July 27, 1926 , Decided *2286 1. … This Board is charged to apply the statute as it finds it, and to assume that Congress intended *2301 it to embrace all cases within the ordinary meaning of the language used.

Garnets v. Commissioner

26 B.T.A. 384 · United States Board of Tax Appeals · Jun 10, 1932

ISIDORE GARNETS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Garnets v. Commissioner Docket Nos. 36598, 45707. … The school has no branches and since 1913 has been *385 registered by the Board of Regents of the State of New York.

Parish-Watson & Co. v. Commissioner

2 B.T.A. 851 · United States Board of Tax Appeals · Oct 16, 1925

Parish-Watson & Co. v. Commissioner Docket No. 2833. United States Board of Tax Appeals 2 B.T.A. 851 ; 1925 BTA LEXIS 2232 ; October 16, 1925 , Decided Submitted June 18, 1925 . *2232 1. … On the same day the first meeting of the board of directors of the corporation was held and the following action was taken by them in regard to the agreement referred to, as shown by the minutes of the board of directors:

Bauer v. Commissioner

2 B.T.A. 147 · United States Board of Tax Appeals · Jun 24, 1925

Bauer v. Commissioner Docket No. 1726. United States Board of Tax Appeals 2 B.T.A. 147 ; 1925 BTA LEXIS 2526 ; June 24, 1925 , Decided Submitted March 26, 1925 . *2526 Ward Loveless, Esq., for the Commissioner.

Evans Prods. Co. v. Commissioner

29 B.T.A. 992 · United States Board of Tax Appeals · Feb 2, 1934

THE EVANS PRODUCTS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Evans Prods. Co. v. Commissioner Docket No. 43044. … Reviewed by the Board. Judgment will be entered under Rule 50.

Fifth Ave. Uniform Co. v. Commissioner

28 B.T.A. 120 · United States Board of Tax Appeals · May 17, 1933

FIFTH AVENUE UNIFORM COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Fifth Ave. Uniform Co. v. Commissioner Docket No. 41297. … United States Board of Tax Appeals 28 B.T.A. 120 ; 1933 BTA LEXIS 1176 ; May 17, 1933 , Promulgated *1176 Respondent allowed amortization deduction in computing deficiency in tax for the fiscal year ending 1918.

Robinson v. Commissioner

21 B.T.A. 677 · United States Board of Tax Appeals · Dec 12, 1930

A. 639, 647), nor upon what may have been the design and purpose of the parties to the transaction (United States v. Phellis, 267 U. S. 156, 172 ). … United States v. Isham, 17 Wall. 496 . Speaking generally, in determining what was actually done in any case, this Board will regard substance rather than form.

Tomfohr v. Commissioner

44 B.T.A. 730 · United States Board of Tax Appeals · Jun 17, 1941

Furthermore, the Board and the courts have refused to enforce transferee liability where the obligation discharged constituted valid prior liens, Union Guardian Trust Co., 41 B. T. A. 1306; Commissioner v. … Phipps v. Sedgwick, 95 U. S. 3 ; Trust Co. v. Sedgwick, 97 U. S. 304 .

Meadows & Co. v. Commissioner

5 B.T.A. 241 · United States Board of Tax Appeals · Oct 27, 1926

MEADOWS & COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Meadows & Co. v. Commissioner Docket No. 114. … United States Board of Tax Appeals 5 B.T.A. 241 ; 1926 BTA LEXIS 2930 ; October 27, 1926 , Decided *2930 In the circumstances of this proceeding, held, that he value of a stock subscription agreement may not be included in

American Peanut Corp. v. Commissioner

6 B.T.A. 1087 · United States Board of Tax Appeals · Apr 29, 1927

AMERICAN PEANUT CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. American Peanut Corp. v. Commissioner Docket No. 6809. … United States Board of Tax Appeals 6 B.T.A. 1087 ; 1927 BTA LEXIS 3323 ; April 29, 1927 , Promulgated *3323 Amounts paid out for the replacement of machinery and equipment destroyed, damaged and replaced as the result of

L. W. Gunby Co. v. Commissioner

3 B.T.A. 714 · United States Board of Tax Appeals · Feb 13, 1926

Gunby Co. v. Commissioner Docket No. 4952. … United States Board of Tax Appeals 3 B.T.A. 714 ; 1926 BTA LEXIS 2583 ; February 13, 1926 , Decided Submitted November 7, 1925 . *2583 On the evidence, held, that the invested capital of the taxpayer should be reduced by

S. C. Toof & Co. v. Commissioner

21 B.T.A. 916 · United States Board of Tax Appeals · Dec 29, 1930

Dry Goods Co. v. United States, 280 U. S. 453 ; and White v. Hood Rubber Co., 280 U. S. 453 . … See United States v. Flannery, 268 U. S. 98 ; and McCaughn v. Ludington, 268 U. S. 106 .

Rowland v. Commissioner

31 B.T.A. 194 · United States Board of Tax Appeals · Sep 21, 1934

ROWLAND, NATIONAL CITY BANK OF NEW YORK, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Rowland v. Commissioner Docket No. 65787. … But see Liberman's Committee v.