Case law

Albatrick, Inc. v. Commissioner

69 T.C.M. 2153 · United States Tax Court · Mar 22, 1995

BROWN, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Albatrick, Inc. v. Commissioner Docket No. 23066-89 United States Tax Court T.C. Memo 1995-119 ; 1995 Tax Ct. … The Browns' 1984 tax year was not before the Court in the Brown case.

Bonn v. Commissioner

34 T.C. 64 · United States Tax Court · Apr 15, 1960

Such instruction and training must meet the requirements both of the YA and of the American Board of Psychiatry and Neurology (hereinafter called the Board). … In 1956 she received a certificate from the Foundation, and in 1957 she was certified by the Board.

Maxwell v. Commissioner

17 T.C. 1589 · United States Tax Court · Mar 26, 1952

We there distinguished the case of Brown v. … The former was considered not taxable in Brown v.

Carver v. Commissioner

10 T.C. 171 · United States Tax Court · Jan 29, 1948

In William Hardy, Inc. v. … v.

Estate of Levin v. Commissioner

90 T.C. 723 · United States Tax Court · Apr 19, 1988

Under Pennsylvania law, Marstan’s obligation under the plan, unless terminated by the board of directors, was fixed and could be enforced by the decedent’s widow at the time of death. See Sotter v. … Davis v. Commissioner, 27 T.C. 378 (1956). Moreover, in this case, we believe the ability of the other board members to go against decedent’s wishes was largely illusory. Petitioner cites Estate of DiMarco v.

Green Bay & Western Railroad v. Commissioner

3 T.C. 372 · United States Tax Court · Feb 28, 1944

The Seventh Circuit recently in Commissioner v. … We think the facts of the instant case are no stronger for the taxpayer than were the facts in Commissioner v. Schmoll Fils Associated, Inc., 110 Fed. (2d) 611.

Schairer v. Commissioner

9 T.C. 549 · United States Tax Court · Sep 30, 1947

Otto Sorg Schairer, Petitioner, v. Commissioner of Internal Revenue, Respondent Schairer v. Commissioner Docket No. 8971 United States Tax Court 9 T.C. 549 ; 1947 U.S. Tax Ct. … See Heiner v. Tindle , 276 U.S. 582 .

Giannini Packing Corp. v. Commissioner

83 T.C. 526 · United States Tax Court · Sep 25, 1984

N.C. 1970); Brown-Forman Distillers Corp. v. United States, 205 Ct. Cl. 402 , 499 F.2d 1263 (1974). … See Commissioner v. Schuyler Grain Co., supra; Brown-Forman Distillers Corp. v. United States, supra; Central Citrus Co. v. Commissioner, 58 T.C. at 372-373 ; Catron v. Commissioner, supra.

Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. Commissioner

139 T.C. 67 · United States Tax Court · Aug 30, 2012

V. … The meeting minutes for QHMC’s board meetings (QHMC board meetings) reflected no discussion of the changes. 51 (QHMC’s board meetings are discussed

Blackburn v. Commissioner

11 T.C. 623 · United States Tax Court · Oct 14, 1948

The Board followed the Stephenson case in a memorandum opinion in the case of Jennie Hobbs Barbour. The Circuit Court of Appeals for the Fifth Circuit reversed in 1937 (see Barbour v. … Rosenberg v. Commissioner, 115 Fed. (2d) 910, and Stella Wheeler Bishop, 4 T. C. 588 ; reversed, 152 Fed. (2d) 389, both involving California community property.

Estate of Wynekoop v. Commissioner

24 T.C. 167 · United States Tax Court · May 6, 1955

based on the Board’s inclusion of the ordinary trust income, it is necessary to state that one of these New York trusts was construed in Morris v. … See Freuler v. Helvering, 291 U. S. 35 (1934); Blair v. Commissioner, 300 U. S. 5 (1937); and Sharp v. Commissioner, 303 U.

Seiners Asso. v. Commissioner

58 T.C. 949 · United States Tax Court · Sep 20, 1972

The notable cases in this area are: Commissioner v. … McCamant, 32 T.C. 824, 834 (1959) ; and Cooperative Oil Assn. v. Commissioner, 115 F. 2d 666 (C.A. 9, 1940), affirming a Memorandum Opinion of the Board of Tax Appeals. See for example Mansuss Realty Co. v.

Fleming v. Commissioner

33 T.C. 336 · United States Tax Court · Nov 27, 1959

set out in column (1) below, and the correct computation, as intended to be reported, is set forth in column (2) below: (1) Enter the income from either line 5 (if separate return) or line 8(a) (if joint return), page 3, (V … , until the decision of the Board becomes final), and for si tty days thereafter.

Kingsbury v. Commissioner

65 T.C. 1068 · United States Tax Court · Mar 3, 1976

Brown , 40 T.C. 861 (1963) . On the other hand, the sale or exchange of an exclusive right to use or possess specific property will produce capital gain. United States v. … Accord Hyatt v. Commissioner, supra ; United States v. Woolsey, supra .

Diggs v. Commissioner

76 T.C. 888 · United States Tax Court · Jun 4, 1981

Judge Brown cataloged some of these in a dissenting opinion in Rudolph v. … The Board of Tax Appeals held to this effect in Darling v. Commissioner, 4 B.T.A. 499 (1926), and respondent states on brief that he does not challenge such a position.

Johnston v. Commissioner

1 T.C. 228 · United States Tax Court · Dec 10, 1942

section 22 (b) (3) of the Revenue Act of 1934 (identical with section 22 (b) (3) of the Revenue Act of 1936), citing Burnet v. … Freuler v. Helvering, 291 U. S. 35 .

Bridgeport Hydraulic Co. v. Commissioner

22 T.C. 215 · United States Tax Court · Apr 30, 1954

Bridgeport Hydraulic Co. v. Kraemer , 119 F. Supp. 924 . Rollin Browne, Esq., Milton D. Solomon, Esq ., and Philo C. Calhoun, Esq ., for the petitioner. Joseph Landis, Esq ., for the respondent. Murdock, Judge . … C. 775 ; Helvering v. California Oregon Power Co ., 75 F. 2d 644 . Cf. Commissioner v. Coastwise Transportation Co ., 62 F. 2d 332 , 71 F. 2d 104 .

Bellefontaine Federal Sav. & Loan Asso. v. Commissioner

33 T.C. 808 · United States Tax Court · Feb 5, 1960

Co. v. Commissioner, 284 U.S. 552, 562 ; Kansas City Southern Ry. Co. v. … Mitchell-Huron Production Credit Ass'n v. Welsh, 163 F. Supp. 883 (D.

Bryant v. Commissioner

46 T.C. 848 · United States Tax Court · Sep 30, 1966

See Commissioner v. Brown, 380 U.S. 563, 575-576 (1965), and Anderson v. Helvering, 310 U.S. 404, 413 (1940). … Commissioner v. Brown, supra at 575-576 ; Commissioner v. Southwest Exploration Co., supra at 912-313 ; Burton-Sutton Oil Co. v. Commissioner, supra at 33 ; Burnet v.

Bergmann v. Commissioner

137 T.C. 136 · United States Tax Court · Oct 11, 2011

Bergmann con- firmed, however, in a letter to his brokerage service provider, Deutsche Bank Alex Brown (DB Alex Brown), a subsidiary of … (136) BERGMANN v.