Case law

Ansorge v. Commissioner

1 T.C. 1160 · United States Tax Court · May 26, 1943

The tenor of the decisions as to the effect of such assignments is well stated in Lopez v. United States, 24 Ct. … Wellington v. Smith, 147 N.

May v. Commissioner

76 T.C. 7 · United States Tax Court · Jan 8, 1981

In Skemp v. Commissioner, 8 T.C. 415 (1947), revd. 168 F.2d 598 (7th Cir. 1948), and Brown v. … Skemp v. Commissioner, 168 F.2d 598 (7th Cir. 1948); Brown v. Commissioner, 180 F.2d 926 (3d Cir. 1950).

Gittens v. Commissioner

49 T.C. 419 · United States Tax Court · Jan 25, 1968

See United States v. Johnson, 331 F. 2d 943 (C.A. 5, 1964); United States v. Martin, 337 F. 2d 171 (C.A. 8, 1964); Harry K. … Schlegel, supra; Rybacki v. Conley, 340 F. 2d 944 (C.A. 2, 1965); Thomas E. Judkins, 31 T.C. 1022 (1959); but it has been seriously questioned by others, e.g., United States v. Johnson, supra; United States v.

First Northwest Industries, Inc. v. Commissioner

70 T.C. 817 · United States Tax Court · Sep 6, 1978

Compare Sunset Fuel Co. v. United States, 519 F.2d 781 , 784 n. 4 (9th Cir. 1975); Manhattan Co. of Virginia, Inc. v. Commissioner, 50 T.C. 78, 91 (1968); Commissioner v. … In Boe v.

Ossorio v. Commissioner

1 T.C. 410 · United States Tax Court · Jan 5, 1943

A. 874; Commissioner v. Rabenold (C. C. A., 2d Cir.), 108 Fed. (2d) 639. The Board later held, however, in George W. Schoenhut, 45 B. T. A. 812, on the authority of Moore v. United States (Ct. Cls.), 37 Fed. … Supp. 136; Helvering v. Janney, 311 U. S. 189 ; and Taft v. Helvering, 311 U. S. 195 , that the liability of spouses filing a joint return was joint and several.

Harmon v. Commissioner

1 T.C. 40 · United States Tax Court · Nov 18, 1942

A. 457, the Board held, expressing approval .of the above quoted portion of G. C. … The cases principally relied upon by the Board in that case were those dealing with losses generally such as United States v. White Dental Manufacturing Co., supra; Royal Packing Co. v. Commissioner (C. C.

Ramos v. Commissioner

38 T.C. 820 · United States Tax Court · Sep 11, 1962

See Lykes v. United States, 343 U.S. 118, 122 ; Bowers v. Lumpkin, 140 F. 2d 927, 928 (C.A. 4). … The United States Court of Appeals for the Fifth Circuit in Brown v. Commissioner, 215 F. 2d 697 , affirming 19 T.C. 87 on this point, also distinguished its earlier case of Allen v.

Clover Farm Stores Corp. v. Commissioner

17 T.C. 1265 · United States Tax Court · Feb 6, 1952

His argument in support of this contention is that under the provisions of article V of the Agreement of Merger the board of directors of petitioner had the power to withhold any part of its earned surplus and place all of … C. 1002 ; Cooperative Oil Assn., Inc. v. Commissioner (C. A. 9), 115 F. 2d 666, 668 ; Uniform Printing & S. Co. v. Commissioner (C. A. 7), 88 F. 2d 75, 76 ; Farmers Cooperative Co. v. Birmingham (N. D. Ia.), 86 F.

Boston Elevated Railway Co. v. Commissioner

16 T.C. 1084 · United States Tax Court · May 16, 1951

United States v. Safety Car Heating Co., 297 U. S. 88, 93-94 ; Lucas v. American Code Co., 280 U. S. 445, 451, 452 . … to discontinue service as of October 1,1938, was made in the light of the opinion of counsel for the board that, while consent of the board to such discontinuance would result in forfeiture of the structure, an independent

Ferguson v. Commissioner

11 T.C.M. 213 · United States Tax Court · Mar 7, 1952

Brown, and Iva I. … Brown, and Iva I.

Williams v. Commissioner

3 T.C. 200 · United States Tax Court · Feb 4, 1944

Colston v. Burnet, 59 Fed. (2d) 867; Automatic Sprinkler Co. of America, 27 B. T. A. 160; Agnes I. Fox, 43 B. T. A. 895; Orange Securities Corporation, 45 B. T. A. 24, 31; Inez H. Brown, 1 T. C. 225 .

American Business Credit Corp. v. Commissioner

9 T.C. 1111 · United States Tax Court · Dec 16, 1947

In one of the earlier cases, LaBelle Iron Works v. United States, 256 U. … -Dec., 1919), the Advisory Tax Board, in T. B.

Deneke v. Commissioner

42 T.C. 981 · United States Tax Court · Aug 27, 1964

Mary’s Academy of Palestine, Tex., and during 1959 the petitioners paid $1,566 for their board, lodging, tuition, and incidental expenses. … In James v.

Hoofnel v. Commissioner

7 T.C. 1136 · United States Tax Court · Nov 12, 1946

See Commissioner v. Fiske's Estate, 128 Fed. (2d) 487; Commissioner v. Swent, 155 Fed. (2d) 513. … Petitioner seems to argue that he was “outside the United States” the moment he boarded the British vessel.

American Participations-Trust Co. v. Commissioner

14 T.C. 1457 · United States Tax Court · Jun 30, 1950

Morrissey v. Commissioner, supra; Helvering v. Coleman-Gilbert Associates, 296 U. S. 369 . … The latter involves questions of fact as to which the Board’s findings are conclusive if supported by the evidence. Helvering v. National Grocery Co., 304 U. S. 282 , 58 S. Ct. 932 , 82 L. Ed. 1346 .

Estate of Baumgardner v. Commissioner

85 T.C. 445 · United States Tax Court · Sep 11, 1985

The Board stated that the controversy before it related "to the question as to whether the Board has jurisdiction to determine whether the amount of interest paid on a conceded overpayment of taxes is an overpayment.” … Kilpatrick’s executor filed a petition with the Board of Tax Appeals to redetermine the deficiency.

Dunavant v. Commissioner

63 T.C. 316 · United States Tax Court · Dec 12, 1974

On November 28, 1969, a meeting of the board of directors was held, the minutes of which read as follows: A special meeting of the Board of Directors was called to order by the President for the specific purpose of discussing … Posey v. United States, 449 F.2d 228 (C.A. 5, 1971), which followed Ralph D. Lambert, supra, was recently cited with approval in William James Hooper, T.C. Memo. 1974-176 . See also Bachman v.

O'Dell v. Commissioner

26 T.C. 592 · United States Tax Court · Jun 20, 1956

On appeal to the Board of Tax Appeals, the Commissioner was reversed. … The Blair v. First Trust & Savings Bank of Miami, Fla., supra, case was followed by the Eighth Circuit in Helvering v.

Indus. Valley Bank & Trust Co. v. Comm'r

66 T.C. 272 · United States Tax Court · May 18, 1976

At the special meeting of the board of directors of Lehigh on December 13, Leon King recommended that Lehigh’s board of directors adopt the resolutions which were adopted. … John Shevets was vice president and treasurer of Lehigh (but not a member of its board of directors).

Great Falls Bonding Agency, Inc. v. Commissioner

63 T.C. 304 · United States Tax Court · Dec 9, 1974

Gordon v. Loew’s, Inc., 147 F.Supp. 398, 403-407 (D.C. N.J. 1956), affd. 247 F.2d 451 (C.A. 3, 1957). See Charles A. Zahn Co. v. United States, 6 F.Supp. 317, 319 (Ct. Cl. 1934), and A. J. Bates Co. v. … maintain its appeal to the Board.