Case law

Spanish Trail Land Co. v. Commissioner

10 T.C. 430 · United States Tax Court · Mar 16, 1948

See Ehrman v. Commissioner, 120 Fed. (2d) 607. … While the facts in Brown v. Commissioner, 143 Fed. (2d) 468, are not the same as those involved in the instant case, we think the language in that case is appropriate to what was done here.

Austin v. Commissioner

35 T.C. 221 · United States Tax Court · Oct 31, 1960

Snyder v. Commissioner, 295 U.S. 134 . The evidence does not point in that direction. We hold that the loss in question was not one incurred in a trade or business. … Heiner v. Tindle, 276 U.S. 582 . Since petitioners in their brief say they “do not claim a conversion of their property,” we need not further pursue that angle.

Papineau v. Commissioner

16 T.C. 130 · United States Tax Court · Jan 19, 1951

Helvering v. Independent Life Ins. Co., 292 U. S. 371 . Cf. T. D. 2665, Vol. 20, p. 45, March 8, 1918. Nor can such expenditures be reflected into income by any mirrors of accounting. … The Commissioner concedes that he boarded and lodged in the hotel for the convenience of the partnership.

Sommerfeld Machine Co. v. Commissioner

11 T.C. 86 · United States Tax Court · Jul 28, 1948

C. 27 ; Pohatcong Hoisiery Mills, Inc. v. Commissioner, 162 Fed. (2d) 146; American Coast Line Co., 6 T. C. 67 ; Blum Folding Paper Box Co., 4 T. C. 795 ; and Ideal Packing Co., 9 T. C. 346 . … The committee reports with respect to section 732 (a) state: Under existing law, unless a deficiency has been determined by the Commissioner, a taxpayer has no right of appeal to the Board (sec. 272 (a) (1), I. R. C.).

McNair v. Commissioner

26 T.C. 1221 · United States Tax Court · Sep 28, 1956

In making our decision herein we are not unmindful of Prince v. United States, (Ct. Cl., 1954) 119 F. … The crucial factual distinction is that in Prince the taxpayer, although retired for age and thereafter recalled to active duty in the armed services, did appear before the appropriate retirement board, which board made a

Mitchell v. Commissioner

80 T.C.M. 590 · United States Tax Court · Oct 26, 2000

Memo. 1995-66 (cited in Butler v. Commissioner, supra at 291). Among other things, she made 5 (...continued) concerning whether Mr. Browne advised petitioner that Mr. … See Terzian v. Commissioner, 72 T.C. 1164, 1172 (1979) (cited in Butler v. Commissioner, supra at 291).

AbbVie Inc. and Subsidiaries

United States Tax Court · Jun 17, 2025

Alderson v. … V.

Estate of Palmer v. Commissioner

86 T.C. 66 · United States Tax Court · Jan 22, 1986

E.g., Palmer v. Commissioner, 523 F.2d 1308, 1310 (8th Cir. 1975), affg. 62 T.C. 684, 696 (1974); McShain v. Commissioner, 71 T.C. 998, 1004 (1979). … Co. v. Commissioner, 74 T.C. 441, 452 (1980).

Wilmot Fleming Engineering Co. v. Commissioner

65 T.C. 847 · United States Tax Court · Jan 29, 1976

Throndson v. Commissioner, 457 F. 2d 1022 (9th Cir. 1972). … Maddock, 16 T.C. 324 (1951); In Re Brown, 242 N.Y. 1 , 150 N.E. 581 (1926), we find that no goodwill was sold by decedent and Wilmot.

Adams v. Commissioner

58 T.C. 41 · United States Tax Court · Apr 17, 1972

In Sun Properties v. … See Herring v.

Moore-McCormack Lines, Inc. v. Commissioner

44 T.C. 745 · United States Tax Court · Aug 27, 1965

See Heiner v. … See Maytag v.

Bear Film Co. v. Commissioner

18 T.C. 354 · United States Tax Court · May 21, 1952

Lucas v. Ox Fibre Brush Co., 281 U. S. 115 : Dixie Pine Products Co. v. Commissioner, 320 U. S. 516 ; Security Flour Mills Co. v. Commissioner, 321 U. S. 281 . … Prior to Oscar’s purchase of the petitioner’s common stock from Quinn in 1927, the petitioner’s board of directors had adopted a resolution increasing Oscar’s salary by $750 per month.

Orr Mills v. Commissioner

30 T.C. 150 · United States Tax Court · Apr 30, 1958

Petitioner, in support of its contention, relies on the rule first enunciated in Commissioner v. Ashland Oil & R. Co., 99 F. 2d 588 , certiorari denied 306 U. … See also Georgia Proferties Co. v. Henslee, 138 F. Supp. 587 .

Newton v. Commissioner

11 T.C. 512 · United States Tax Court · Sep 30, 1948

Since the action of the board of directors of Finance was pursuant to authority of the stockholders, such cases as Noel v. Parrott, supra, have no application here. … Noel v. Parrott, 15 Fed. (2d) 669.

Seattle Brewing & Malting Co. v. Comm'r

6 T.C. 856 · United States Tax Court · Apr 29, 1946

In Commissioner v. … Green v. LeClair, 24 Fed. (2d) 74. In Waterman v.

Frantz v. Commissioner

83 T.C. 162 · United States Tax Court · Aug 7, 1984

At the special meeting of the board of directors of ABL held on June 30,1971, the board of directors adopted a plan to offer stock under section 1244, I.R.C. 1954. … It was agreed that all members of the board actively would seek additional financing. At a January 4, 1973, meeting of the board, board members discussed their progress in seeking outside investors. Messrs.

Pollei v. Commissioner

94 T.C. 595 · United States Tax Court · Apr 18, 1990

Early in the history of this Court, the Board of Tax Appeals had occasion to decide an issue somewhat similar to the one confronting us now. See Peavy-Byrnes Lumber Co. v. … On remand, the taxpayer moved the Board for leave to amend its pleading to present a new issue not previously raised and considered by the Board or the Court of Appeals.

Langley Park Apartments, Sec. C, Inc. v. Commissioner

44 T.C. 474 · United States Tax Court · Jun 25, 1965

The entries were made pursuant to instructions of petitioner’s board of directors. … V.

Lamb v. Commissioner

50 T.C.M. 1209 · United States Tax Court · Sep 30, 1985

LAMB, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Lamb v. Commissioner Docket Nos. 8575-76, 8555-79, 8556-79, 8557-79. United States Tax Court T.C. Memo 1985-512 ; 1985 Tax Ct. … Spies v. Commissioner, supra at 499.

Lincoln Sav. & Loan Asso. v. Commissioner

51 T.C. 82 · United States Tax Court · Oct 21, 1968

See and compare Commissioner v. Boylston Market Assn., 131 F. 2d 966 (C.A. 1), affirming a Memorandum Opinion of the Board of Tax Appeals, with Waldheim Realty & Inv. Co. v. … Co. v.