Case law

Estate of Simplot v. Comm'r

112 T.C. 130 · United States Tax Court · Mar 22, 1999

FPG provides this market with several potato products (including a variety of french-fry products, hash browns, and cubed potatoes). J.R. … Simplot was on the board of directors, the other board members usually adhered to his business and policy decisions. Although J.R.

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.

Scio Oil & Gas Co. v. Commissioner

28 T.C. 426 · United States Tax Court · May 23, 1957

Compare Burnet v. Harmel, 287 U. … C. 1113 , this Court followed the decision in Magruder v. Supplee, supra, in a case which involved taxes of the State of Delaware.

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.

Hudson City Sav. Bank v. Commissioner

53 T.C. 70 · United States Tax Court · Oct 23, 1969

Bulova Watch Co. v. United States, 365 U.S. 753 (1961). … The facts are strikingly similar to those present in the leading case of United States v.

Pityo v. Commissioner

70 T.C. 225 · United States Tax Court · May 15, 1978

During 1972 petitioner was a stockholder and a member of the board of directors of the Marine Bank of St. Petersburg. … See Brown v. Commissioner, 180 F.2d 926,929 (3d Cir. 1950), revg. 12 T.C. 1095 (1949), cert. denied 340 U.S. 814 (1950); Oakes v. Commissioner, 44 T.C. 524, 529 (1965); Felix v. Commissioner, 21 T.C. 794, 804 (1954).

Longhorn Portland Cement Co. v. Commissioner

3 T.C. 310 · United States Tax Court · Feb 21, 1944

Deputy v. Du Pont, 308 U. S. 488 , 495 * * *; Welch v. Helvering, 290 U. S. 111 , 114 * * *; Kornhauser v. United States, supra. … However, the Seventh Circuit refused to follow the reasoning of the Second Circuit and reversed the Board.

Aircraft & Diesel Equipment Corp. v. Stimson

5 T.C. 362 · United States Tax Court · Jun 30, 1945

Aircraft & Diesel Equipment Corporation, a Corporation, Petitioner, v. Henry L. Stimson, Secretary of War, and Robert P. Patterson, Under Secretary of War, Respondents Aircraft & Diesel Equipment Corp. v. … Francis Hill, Esq ., for the petitioner. *130 William V. Crosswhite, Esq ., for the respondents. Murdock, Judge . MURDOCK *362 OPINION.

American Bantam Car Co. v. Commissioner

11 T.C. 397 · United States Tax Court · Sep 27, 1948

Louangel Holding Corporation v. Anderson, 9 Fed. Supp. 550. … Using these tests as a basis for their decisions the courts in Hazeltine Corporation v. Commissioner, 89 Fed. (2d) 513, and Bassick v.

Verifine Dairy Products Corp. of Sheboygan v. Commissioner

3 T.C. 269 · United States Tax Court · Feb 15, 1944

The Seventh Circuit, in Commissioner v. … A very similar provision was present in Parisian, Inc. v. Commissioner, 131 Fed. (2d) 394, affirming memorandum opinion of the Board.

General Smelting Co. v. Commissioner

4 T.C. 313 · United States Tax Court · Nov 15, 1944

Lewis Thomas, chairman of its board of directors, $14,400. … Lucas v. Ox Fibre Brush Co., 281 U. S. 115 .

American Stores Co. v. Commissioner

114 T.C. 458 · United States Tax Court · May 26, 2000

On May 23, 1988, the board of directors for Lucky Stores approved the amended tender offer and a merger proposal with American Stores. … In Brown v. United States, 526 F.2d 135, 139 (6th Cir. 1975), legal expenses paid in settlement of a derivative action were held to be nondeductible capital expenditures.

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.).

H. F. Ramsey Co. v. Commissioner

43 T.C. 500 · United States Tax Court · Jan 28, 1965

Browning (hereafter referred to as Browning) has been a director and secretary-treasurer of petitioner from 1951 to date. … Any checks drawn on the account were to be jointly signed by Ramsey and Browning and approved by designated persons.

Newlin Machinery Corp. v. Commissioner

28 T.C. 837 · United States Tax Court · Jun 28, 1957

State v. Board of Commissioners of Republic County, (Kans. 1938) 82 P. 2d 84, 88 ; Shouse v. … State v. Board of Education of Topeka, 21 P. 2d 295 .

Katz v. Commissioner

90 T.C. 1130 · United States Tax Court · Jun 15, 1988

Sochin v. Commissioner, 843 F.2d 351 , 353 n. 6 (9th Cir. 1988), affg. Brown v. Commissioner, 85 T.C. 968, 998 (1985); Forseth v. Commissioner, 85 T.C. 127, 166 (1985), affd. 845 F.2d 746 (7th Cir. 1988), affd. sub nom. … See Enrici v. Commissioner, 813 F.2d at 295 note 1; Brown v. Commissioner, 85 T.C. at 998, 1000; Forseth v. Commissioner, 85 T.C. at 166 n. 43.

Moore-McCormack Lines, Inc. v. Commissioner

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

See Heiner v. … See Maytag v.

Carpenter v. Commissioner

36 T.C. 797 · United States Tax Court · Jul 31, 1961

Pinkerton, 28 T.C. 910 (1957); United States v. Johnson.| 257 F. 2d 530 (C.A. 9, 1958); Gilmore v. United States, 180 F. Supp. 354 (Ct. Cl. 1960); and Wirkkala v. United States, 181 F. Supp. 338 (W. D. Wash. 1960). … Decision will he entered v/nder Rule 50. SEC 631. GAIN OR LOSS IN THE CASE OP TIMBER OR COAL.

Meurlin v. Commissioner

25 T.C. 118 · United States Tax Court · Oct 27, 1955

Brown, M. … Co. v. Commissioner, 222 F. 2d 355 .

Penn-Dixie Steel Corp. v. Commissioner

69 T.C. 837 · United States Tax Court · Feb 27, 1978

See Clodfelter v. … See Hoven v. Commissioner, supra; United States Industrial Alcohol Co. v.