Case law

Yari v. Commissioner

143 T.C. 157 · United States Tax Court · Sep 15, 2014

See Callahan v. … We interpret statutes ‘‘ ‘in their context and with a view to their place in the overall statutory scheme.’ ’’ FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 133 (2000) (quoting Davis v. Mich.

Cleary v. Commissioner

60 T.C. 133 · United States Tax Court · Apr 25, 1973

Brooks v. United States, 473 F. 2d 829, 831 (C.A. 6, 1973). … See and compare, e.g., Prince v. United States, 127 Ct. Cl. 612, 614-615 , 119 F. Supp. 421, 422 (1954); McNair v. Commissioner, 250 F. 2d 147, 150 (C.A. 4, 1957), reversing 26 T.C. 1221 (1956); Freeman v.

Brown v. Commissioner

7 T.C. 715 · United States Tax Court · Sep 10, 1946

Brown v. Commissioner

78 T.C. 215 · United States Tax Court · Feb 8, 1982

Brown and Mrs. Barbara J. Brown MKSAC/KKMAC Box 3354 APO New York, New York 09615 By letter dated February 15, 1980, petitioner Henry M. … Brown Henry M. Brown hmb/ All future correspondence should be directed to our Saudi Address Henry M.

Brown v. Commissioner

1 T.C. 225 · United States Tax Court · Dec 9, 1942

Radford_ 10.14 7.86 Inez Hereford Brown_ 10.14 7.86 * * * * * * * Thereafter, on March 24,1939, stipulations of gift tax deficiencies for the two years were filed with the Board in pursuance of said agreement and the Board … Colston v. Burnet, 59 Fed. (2d) 867, affirming 21 B. T. A. 396; Automatic Sprinkler Co. of America, 27 B. T. A. 160; Helen B. Sulzberger, 33 B. T. A. 1093; William H. Simon, 36 B. T. A. 184; Chester A.

Brown v. Commissioner

48 T.C. 42 · United States Tax Court · Apr 19, 1967

Petitioner and Norma Peene Brown were married in 1957, separated in November 1961, and divorced on February 21,1962. … As a consequence, Commissioner v. Mendel, 351 F. 2d 580 (C.A. 4, 1965), reversing 41 T.C. 32 (1963), so heavily relied on by petitioner, is clearly distinguishable. Cf. Edward J. Pillis, 47 T.C. 707 (1967).

Brown v. Commissioner

85 T.C. 968 · United States Tax Court · Dec 18, 1985

In Falsetti v. … In Oneal v.

Brown v. Commissioner

37 T.C. 461 · United States Tax Court · Dec 19, 1961

Also, the amount per thousand feet used in determining adjusted values was $8.20 per thousand board feet whereas Clay Brown & Company had received an independent appraisal as of May 1,1952, of $9 per thousand board feet. … Helvering, 293 U.S. 465 (1935); Higgins v. Smith, 308 U.S. 473 (1940); Griffiths v. Helvering, 308 U.S. 355 (1939); and Burnet v. Harmel, 287 U.S. 103 (1932).

Brown v. Commissioner

12 T.C. 1095 · United States Tax Court · Jun 21, 1949

Johnson v. Commissioner, 86 Fed. (2d) 710, affirming 33 B. T. A. 1003. Neither the mechanics employed nor the legal designations, i. e., “rents” and/or “royalties,” are controlling. … Manning v. Gagne, 27 Fed. Supp. 286; affd., 108 Fed. (2d) 718; Smith v. Hoey (unreported officially, Dis. Ct. N. Y.), 34 A. F. T. R. 1704; affd., 153 Fed. (2d) 846; Percy C. Madeira, 36 B. T.

Brown v. Commissioner

50 T.C. 865 · United States Tax Court · Sep 16, 1968

Douglas v. Willcuts, 296 U.S. 1 (1935); Helvering v. Fitch, 309 U.S. 149 (1940); Commissioner v. Lester, 366 U.S. 299 (1961). … In Foster v.

Brown v. Commissioner

47 T.C. 399 · United States Tax Court · Jan 18, 1967

Brown, was an active member of the Memphis local council 74 of ALPA. Brown was an apprentice member of such council. … In Commissioner v.

Brown v. Commissioner

51 T.C. 116 · United States Tax Court · Oct 22, 1968

In formulating a standard of duress applicable in Federal tax controversies, the Court of Appeals in Furnish v. … Thurston Brown are still outstanding and collectable from his real or personal property. Thus respondent is not left without recourse against E. Thurston Brown.

Brown v. Commissioner

27 T.C. 27 · United States Tax Court · Oct 18, 1956

Sun Properties, Inc. v. United States, 220 F. 2d 171 ; Marjory Taylor Hardwick, 33 B. T. A. 249; W. A. Hoult, 23 B. T. A. 804. … Sun Properties, Inc. v. United States, supra, is directly in point here. There, the taxpayer corporation was formed by its sole stockholder on August 25, 1947.

Brown v. Commissioner

25 T.C. 220 · United States Tax Court · Oct 31, 1955

. * * * However, in Waller v. United States, 180 F. 2d 194 , the Court of Appeals for the District of Columbia in considering disability payments received, under the Public Health Service Act, disallowed the exemption. … The injury, which is described in the official report as a turned ankle, occurred 20 years prior to Brown’s retirement, and during such, period he continued to serve as a walking policeman.

Brown v. Commissioner

40 T.C. 861 · United States Tax Court · Aug 16, 1963

Brown (hereinafter sometimes referred to as petitioner) and Sydney N. Brown are husband and wife residing in Ridgeland, S.C. … Brown, by signing this agreement hereby resigns from the Board of Directors of United American Life Insurance Company and United American Investment Company, as a member of the Executive and Finance Committees of the United

Brown v. Commissioner

22 T.C. 147 · United States Tax Court · Apr 27, 1954

Raybestos-Manhattan, Inc. v. United States, 296 U. S. 60, 64 . See also Helvering v. Horst, 311 U. … S. 1 ; Helvering v. American Chicle Co., 291 U. S. 426 ; Old Colony Trust Co. v. Commissioner, supra; United States v. Boston & Maine Railroad, supra; United States v. Hendler, 303 U. S. 564 ; Douglas v.

Brown v. Commissioner

23 T.C. 156 · United States Tax Court · Oct 29, 1954

In Commissioner v. Highway Trailer Co., 72 F. 2d 913 , certiorari denied 293 U. S. 626 , rehearing denied 294 U. … We think that this does not conflict with the rule of the Huff Case, supra [Burnet v. Huff, 288 U.

Brown v. Commissioner

30 T.C. 831 · United States Tax Court · Jun 30, 1958

Mayherry v. Carey, 268 Mass. 255 , 167 N. E. 281 ; Dumaine v. Dumaine, supra; Sears v. Childs, 309 Mass. 337 , 35 N. E. 2d 663 . … Offut v. Offut, 204 Md. 101 , 102 A. 2d 554, 558 (1954). Restatement, Trusts, sec. 187, which was cited with approval by the court in Offut v.

Brown v. Commissioner

73 T.C. 156 · United States Tax Court · Oct 24, 1979

The taxpayer who has been working part time is offered a position involving full-time employment which she can accept only if the child is placed in a boarding school. … The taxpayer accepts the position, and the child is sent to a boarding school.

Brown v. Commissioner

62 T.C. 551 · United States Tax Court · Jul 30, 1974

Donnelly v. Commissioner, 262 F. 2d 411, 413 (C.A. 2, 1959), affirming 28 T.C. 1278 (1957). See also John J. Thoene, 33 T.C. 62 (1959). … The United States Court of Appeals for the District of Columbia in Founding Church of Scientology v.