Case law

Penn v. Commissioner

39 B.T.A. 787 · United States Board of Tax Appeals · Apr 19, 1939

PENN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Penn v. Commissioner Docket No. 90760. … Clifford, Docket No. 89054, an unreported memorandum opinion of this Board entered September 26, 1938.

Grimmer v. Commissioner

3 B.T.A. 313 · United States Board of Tax Appeals · Jan 14, 1926

Grimmer v. Commissioner Docket No. 3393. United States Board of Tax Appeals 3 B.T.A. 313 ; 1926 BTA LEXIS 2699 ; January 14, 1926 , Decided Submitted October 15, 1925 . *2699 Clyde H. Hunter, C.P.A., for the taxpayer.

Estate of Hunt v. Commissioner

19 B.T.A. 624 · United States Board of Tax Appeals · Apr 16, 1930

See also Ewalt v. Ames, 6 Ohio App. 374 ; McCoy v. … Reviewed by the Board. Judgment will he entered under Rule 60.

W. H. Hartman Co. v. Commissioner

20 B.T.A. 302 · United States Board of Tax Appeals · Jul 22, 1930

HARTMAN CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. W. H. Hartman Co. v. Commissioner Docket No. 40208. … The Board allowed the deduction thereof, having found they were related to the petitioner's business. Those opinions are not authority, therefore, for the respondent's determination in this proceeding.

Tyler v. Commissioner

9 B.T.A. 255 · United States Board of Tax Appeals · Nov 23, 1927

Tyler v. Commissioner Docket No. 3875. United States Board of Tax Appeals 9 B.T.A. 255 ; 1927 BTA LEXIS 2625 ; November 23, 1927 , Promulgated *2625 1. … Reviewed by the Board. Judgment will be entered for the Commissioner. MILLIKEN did not participate.

Monarch Elec. & Wire Co. v. Commissioner

12 B.T.A. 158 · United States Board of Tax Appeals · May 28, 1928

MONARCH ELECTRIC & WIRE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Monarch Elec. & Wire Co. v. Commissioner Docket No. 13405. … Reviewed by the Board. Judgment will be entered under Rule 50.

Rollins v. Commissioner

34 B.T.A. 319 · United States Board of Tax Appeals · Apr 14, 1936

United States v. Isham, 17 Wall. 496 ; Bullen v. State of Wisconsin, 240 U. S. 625 ; Gregory v. Helvering, 293 U. S. 465 ; Chisholm v. Commissioner, 79 Fed. (2d) 14. … Sawtell v.

Fawkes v. Commissioner

25 B.T.A. 366 · United States Board of Tax Appeals · Jan 26, 1932

FAWKES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Fawkes v. Commissioner Docket No. 21992. … United States Board of Tax Appeals 25 B.T.A. 366 ; 1932 BTA LEXIS 1532 ; January 26, 1932 , Promulgated *1532 Losses claimed as deductions from income in the years 1922 and 1923 disallowed. Clarence T.

U. S. Universal Joints Co. v. Commissioner

46 B.T.A. 111 · United States Board of Tax Appeals · Jan 20, 1942

The Board held that in fact a part of the “royalties” was compensation for services rendered by the licensor to the licensee in accordance with a provision of the agreement which was as follows: * * * “The licensor agrees … Noteman v. Welch, 108 Fed. (2d) 206; Logan Coal & Timber Association, 42 B. T. A. 529, and Lane-Wells Co., supra, are cases relied upon by the respondent. They are distinguishable upon their facts.

Pelican Bay Lumber Co. v. Commissioner

9 B.T.A. 1024 · United States Board of Tax Appeals · Jan 3, 1928

PELICAN BAY LUMBER CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Pelican Bay Lumber Co. v. Commissioner Docket No. 6354. … The petitioner has cited several decisions of this Board in support of its petition but we do not consider that they are *4313 in point here and we deem it unnecessary to discuss them.

Keighley Mfg. Co. v. Commissioner

2 B.T.A. 10 · United States Board of Tax Appeals · Jun 9, 1925

Co. v. Commissioner Docket No. 2607. United States Board of Tax Appeals 2 B.T.A. 10 ; 1925 BTA LEXIS 2586 ; June 9, 1925 , Decided Submitted April 29, 1925 . *2586 A. H.

McClure Pine Co. v. Commissioner

20 B.T.A. 560 · United States Board of Tax Appeals · Aug 13, 1930

MCCLURE PINE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. McClure Pine Co. v. Commissioner Docket Nos. 37009, 41314. … Hemphill to build a fully equipped sawmill with planers, dry kiln, etc., capable of manufacturing a million board feet of lumber a month.

Metzger v. Commissioner

5 B.T.A. 1230 · United States Board of Tax Appeals · Jan 27, 1927

METZGER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Metzger v. Commissioner Docket No. 9682. … United States Board of Tax Appeals 5 B.T.A. 1230 ; 1927 BTA LEXIS 3644 ; January 27, 1927 , Promulgated *3644 C. R. Fletcher, Esq., for the petitioner. Henry Ravenel, Esq., for the respondent.

Brawner v. Commissioner

15 B.T.A. 1122 · United States Board of Tax Appeals · Mar 27, 1929

A. 477; Rodenbough v. United States, 25 Fed. (2d) 13. Reviewed by the Board. Decision will be entered under Bule 50.

David Rodefer Oil Co. v. Commissioner

11 B.T.A. 782 · United States Board of Tax Appeals · Apr 23, 1928

In United States v. … The facts in this case are parallel to those considered by the Board in G. L. Ramsey, 11 B. T. A. 345. In accordance therewith the deficiency assessment is collectible.

Leggett & Platt Spring Bed Mfg. Co. v. Commissioner

18 B.T.A. 1012 · United States Board of Tax Appeals · Feb 3, 1930

In many decided cases this Board has held that a patent is a de-preciable asset, exhaustible ratably over the term for which it is issued. Union Metal Manufacturing Co., 1 B. T. A. 395; St. Louis Screw Co., 2 B. T. … Red Wing Malting Co. v. Willcuts, 15 Fed. (2d) 626; Manhattan Brewing Co., 6 B. T. A. 952. The evidence as to the second group of patents alleged to have been acquired in 1914 at cost of $95,000 is not clear.

Diamond Shoe Co. v. Commissioner

15 B.T.A. 826 · United States Board of Tax Appeals · Mar 12, 1929

DIAMOND SHOE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Diamond Shoe Co. v. Commissioner Docket No. 3453. … Reviewed by the Board. Judgment will be entered under Rule 50. Footnotes 1. Not in existence Aug. to Dec. 31. ↩

O'Toole v. Commissioner

12 B.T.A. 769 · United States Board of Tax Appeals · Jun 22, 1928

O'TOOLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. O'Toole v. Commissioner Docket No. 19402. … Reviewed by the Board. Judgment *3465 will be entered under Rule 50.

Fred Fear & Co. v. Commissioner

9 B.T.A. 34 · United States Board of Tax Appeals · Nov 10, 1927

FRED FEAR & CO., INC., AND BOYCE EXTRACT CO., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Fred Fear & Co. v. Commissioner Docket No. 9327. … At the board-of-directors meeting following the close of 1918 held by the Doxsee Co., the resume of the 1918 events was submitted.

George D. Davidson Co. v. Commissioner

14 B.T.A. 91 · United States Board of Tax Appeals · Nov 12, 1928

DAVIDSON COMPANY OF CALIFORNIA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. George D. Davidson Co. v. Commissioner Docket No. 14659. … The principle has been followed by this Board in numerous decisions respecting other deductions allowed by the statute, and we are of opinion that the rule, in pari materia, should apply here.