Case law

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 .

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.

Kutz v. Commissioner

5 B.T.A. 239 · United States Board of Tax Appeals · Oct 27, 1926

KUTZ, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Kutz v. Commissioner Docket No. 5309. … United States Board of Tax Appeals 5 B.T.A. 239 ; 1926 BTA LEXIS 2928 ; October 27, 1926 , Decided *2928 The amounts paid as premiums on life insurance may not be deducted from gross income in the computation of net income

Milwaukee Gas Specialty Co. v. Commissioner

1 B.T.A. 22 · United States Board of Tax Appeals · Oct 24, 1924

Milwaukee Gas Specialty Co. v. Commissioner Docket No. 138. … United States Board of Tax Appeals 1 B.T.A. 22 ; 1924 BTA LEXIS 270 ; October 24, 1924 , decided Submitted October 16, 1924 . *270 Appeal being from rejection of claim for refund of additional amount of tax paid before June

L. Z. Dickey Grocery Co. v. Commissioner

1 B.T.A. 108 · United States Board of Tax Appeals · Nov 29, 1924

Dickey Grocery Co. v. Commissioner Docket No. 156. … Dickey, president of the taxpayer corporation, was sworn and testified as a witness on behalf of the taxpayer, and from the documentary and oral evidence the Board makes the following FINDINGS OF FACT. 1.

Terrell Co. v. Commissioner

9 B.T.A. 1131 · United States Board of Tax Appeals · Jan 10, 1928

Upon authority of Pollock v. Loan & Trust Co., 157 U. S. 429; Peck v. Lowe, 247 U. … Reviewed by the Board. Decision will be entered for the respondent.

Bartles-Scott Oil Co. v. Commissioner

2 B.T.A. 16 · United States Board of Tax Appeals · Jun 10, 1925

Bartles-Scott Oil Co. v. Commissioner Docket No. 1214. United States Board of Tax Appeals 2 B.T.A. 16 ; 1925 BTA LEXIS 2575 ; June 10, 1925 , Decided Submitted May 19, 1925 . *2575 1. … From the pleadings and the stipulations filed at the hearing the Board makes the following FINDINGS OF FACT. 1. The taxpayer is a Minnesota corporation with its principal office at Willmar. 2.

Panhandle Refining Co. v. Commissioner

45 B.T.A. 651 · United States Board of Tax Appeals · Nov 12, 1941

PANHANDLE REFINING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Panhandle Refining Co. v. Commissioner Docket No. 103637. … The accrual of interest upon monthly balances was done under the instructions of the board of directors of the petitioner.

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.

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.

Phipps v. Commissioner

43 B.T.A. 790 · United States Board of Tax Appeals · Feb 28, 1941

In Guggenheim v. … Guggenheim v. Rasquin, supra; United States v. Ryerson, supra.

Lynn Ideal Shoe Co. v. Commissioner

1 B.T.A. 998 · United States Board of Tax Appeals · Apr 13, 1925

Lynn Ideal Shoe Co. v. Commissioner Docket No. 1699. United States Board of Tax Appeals 1 B.T.A. 998 ; 1925 BTA LEXIS 2718 ; April 13, 1925 , decided Submitted April 6, 1925 . *2718 Samuel J.

Sheakley & Kennedy Bros. v. Commissioner

7 B.T.A. 1156 · United States Board of Tax Appeals · Aug 23, 1927

SHEAKLEY & KENNEDY BROTHERS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Sheakley & Kennedy Bros. v. Commissioner Docket No. 6282. … United States Board of Tax Appeals 7 B.T.A. 1156 ; 1927 BTA LEXIS 3005 ; August 23, 1927 , Promulgated *3005 John C. Loeffler, Esq., for the petitioner. James A. O'Callaghan, Esq., for the respondent.

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:

Winter Garden, Inc. v. Commissioner

10 B.T.A. 71 · United States Board of Tax Appeals · Jan 21, 1928

THE WINTER GARDEN, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Winter Garden, Inc. v. Commissioner Docket No. 8246. … United States Board of Tax Appeals 10 B.T.A. 71 ; 1928 BTA LEXIS 4189 ; January 21, 1928 , Promulgated *4189 1.

Jenks v. Commissioner

3 B.T.A. 596 · United States Board of Tax Appeals · Feb 4, 1926

Jenks v. Commissioner Docket No. 3392. United States Board of Tax Appeals 3 B.T.A. 596 ; 1926 BTA LEXIS 2618 ; February 4, 1926 , Decided Submitted November 11, 1925 . *2618 Isaac C. Jenks pro se. George G.

Tisdale Lumber Co. v. Commissioner

5 B.T.A. 752 · United States Board of Tax Appeals · Dec 8, 1926

Tisdale Lumber Co. v. Commissioner Docket No. 5529. … United States Board of Tax Appeals 5 B.T.A. 752 ; 1926 BTA LEXIS 2796 ; December 8, 1926 , Promulgated *2796 The Board is unable from the evidence submitted to determine the value of alleged good will acquired for stock in

Stein v. Commissioner

4 B.T.A. 1051 · United States Board of Tax Appeals · Sep 25, 1926

Stein v. Commissioner Docket No. 5313. United States Board of Tax Appeals 4 B.T.A. 1051 ; 1926 BTA LEXIS 2104 ; September 25, 1926 , Decided *2104 Abraham Tumaroff, Esq., for the petitioner. F. O.

LCKELHEIMER v. COMMISSIONER

45 B.T.A. 478 · United States Board of Tax Appeals · Oct 24, 1941

PAULINE LCKELHEIMER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. LCKELHEIMER v. COMMISSIONER Docket No. 103425. … Reviewed by the Board. Decision will be entered under Rule 50. STERNHAGEN, MELLOTT, ARNOLD, TYSON, and OPPER dissent. Footnotes 1. SEC. 301. DISALLOWED DEDUCTIONS.

Gerstle v. Commissioner

33 B.T.A. 830 · United States Board of Tax Appeals · Dec 31, 1935

GERSTLE, PETITIONER, ET AL., 1 v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Gerstle v. … Brown, C.P.A., for the petitioners. Dean Kimball, Esq., for the respondent.