Case law

Feldman v. Commissioner

86 T.C. 458 · United States Tax Court · Mar 25, 1986

Feldman attends the board of directors meetings; although he has no vote, Feldman on occasion will address the board of directors on an issue that he feels strongly about. … See Haverhill Shoe Novelty Co. v. Commissioner, 15 T.C. 517 (1950).

Clark v. Commissioner

17 T.C. 1357 · United States Tax Court · Feb 20, 1952

Petitioners were not on the board of directors of the Foundation-trustee-beneficiary and have not attempted to control its decisions. Of the nine board members, only three appear to be related to petitioners. … Similarly in Commissioner v.

Dillard Paper Co. v. Commissioner

42 T.C. 588 · United States Tax Court · Jun 17, 1964

The members of the Committee shall be appointed from time to time by the Board to serve without compensation at the pleasure of the Board, but a member may resign at any time. … Hydro Molding Co., 38 T.C. 312 (1962); Radom & Neidorff, Inc. v. United States, 281 F. 2d 461 (Ct. Cl. 1960).

Alexander v. Commissioner

26 T.C. 856 · United States Tax Court · Jul 20, 1956

Alexander, Petitioners, v. Commissioner of Internal Revenue, Respondent Alexander v. Commissioner Docket No. 52565 United States Tax Court 26 T.C. 856 ; 1956 U.S. Tax Ct. … The petitioner advised Brown that he was not interested in selling them but, after a second visit from Brown, he told Brown that he would think it over and contact him if he did decide to sell the notes.

Estate of Foote v. Commissioner

28 T.C. 547 · United States Tax Court · May 29, 1957

The board of directors of the corporation knew of this family situation. … See Fisher v. Commissioner, 59 F. 2d 192 (C. A. 2). And this in turn depends upon the facts of the particular case. See Alice M. Macfarlane, 19 T. C. 9 ; Estate of Arthur W. Hellstrom, 24 T. C. 916 .

Marsh v. Commissioner

12 T.C. 1083 · United States Tax Court · Jun 17, 1949

McFeely v. Commissioner 296 U. S. 102 , 56 S. Ct. 54 , 80 L. Ed. 83 , 101 A. L. R. 304. … Brewster v. Gage, 280 U. S. 327 , 50 S. Ct. 115 , 74 L. Ed. 457 ; Fordyce v. Helvering, * * * 76 F. 2d 431 . We think that the above decisions are controlling in the instant proceedings.

Bolles v. Commissioner

69 T.C. 342 · United States Tax Court · Nov 30, 1977

In Hirsch v. … Le Vant v. Commissioner, 376 F.2d 434 (7th Cir. 1967); Hirsch v. Commissioner, supra at 135-136; Husted v. Commissioner, 47 T.C. 664, 678-679 (1967).

Victor E. Gidwitz Family Trust v. Commissioner

61 T.C. 664 · United States Tax Court · Feb 21, 1974

Henry Crown was chairman of the board of directors of Material Service. … Gilmore, 372 U.S. 39 (1963); Woodward v. Commissioner, 397 U.S. 572 (1970); United States v. Hilton Hotels, 397 U.S. 580 (1970).

Helfrich v. Commissioner

25 T.C. 404 · United States Tax Court · Dec 7, 1955

Brown, 24 T. C. 256 ; Myrtle O. Calhoun, 23 T. C. 4 . … McCord v. Granger, 201 F. 2d 103 .

The Church of Eternal Life & Liberty, Inc. v. Commissioner

86 T.C. 916 · United States Tax Court · Apr 29, 1986

After evaluation, the minister submits a recommendation to petitioner’s board of directors. The final decision on whether to accept or reject an applicant for membership is made by vote of the board. … None has been approved by petitioner’s board as a member of CELL. The same day that Anna Bowling’s “student” status was terminated, her membership on petitioner’s board of directors was terminated.

Chase v. Commissioner

19 T.C.M. 234 · United States Tax Court · Mar 24, 1960

DeFobio, since 9/1/53 V. G. Brown Treasurer - E. E. DeFobio Secretary - V. G. Brown, resigned 9/1/53 Paul Croll, from 9/1/53 Asst. … DeFobio, from 9/1/53 V. G. Brown, until 4/8/53 Treasurer - E. E. DeFobio Fred Dye, from 4/8/53 Secretary - V. G. Brown, until 9/1/53; then Paul Croll Asst.

Hunt v. Commissioner

22 T.C. 228 · United States Tax Court · Apr 30, 1954

App. 2d 94 , 146 P. 2d 279 (1944); Brown v. Brown, 170 Cal. 1 , 147 P. 1168 (1915). An interlocutory decree may provide for a division of community property and adjudicate community property rights. … Beemer v. Roher, 137 Cal. App. 293 , 30 P. 2d 547 (1934) ; Britton v. Bryson, 216 Cal. 362 , 14 P. 2d 502 (1932).

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.

National Asso. of American Churches v. Commissioner

82 T.C. 18 · United States Tax Court · Jan 5, 1984

The incorporators and board of directors of petitioner are unrelated individuals all of whom reside in close proximity to Independence, Mo. … Memo. 1982-670 ; Schilberg v. Commissioner, T.C. Memo. 1982-336 ; Riemers v. Commissioner, T.C. Memo. 1981-456 ; Kellman v. Commissioner, T.C. Memo. 1981-615 ; and Brown v. Commissioner, T.C.

Taylor v. Commissioner

2 T.C. 267 · United States Tax Court · Jun 25, 1943

Thus, in Retirement Board of Allegheny County v. … Dodge v. Board of Education is inapplicable, as was pointed out in Abrahams v.

Roberts Filter Mfg. Co. v. Commissioner

10 T.C. 26 · United States Tax Court · Jan 8, 1948

The first Board of Managers *303 shall be: Charles V. Roberts, Charles F. Thomas, F. R. Haddock, E. Wallace Chadwick, Esq., and Edgar W. Freeman. … In Lincoln Electric Co. v.

Andrus Trust v. Commissioner

7 T.C. 573 · United States Tax Court · Aug 16, 1946

In its opinion the Board pointed out that “Section 162 (a) allows a deduction under entirely different circumstances from those described in (b) or (c). … In Old Colony Trust Co. v. Commissioner, 301 U. S. 379 , the Supreme Court construed section 162 (a) as allowing deductions to the full extent of the gross income.

Hoffman v. United States

23 T.C. 569 · United States Tax Court · Dec 31, 1954

Warner v. War Contracts Price Adjst. Board, 14 T. C. 1320 (1950). Upon the record before us, we have found as a fact that petitioner and the Corporation were under common control. … Moening v. War Contracts Price Adjustment Board, 14 T. C. 589 (1950).

Warren Browne, Inc. v. Commissioner

14 T.C. 1056 · United States Tax Court · Jun 5, 1950

Warren Browne, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Warren Browne, Inc. v. Commissioner Docket No. 22176 United States Tax Court 14 T.C. 1056 ; 1950 U.S. Tax Ct. … Goldberg, and48 per cent of the outstanding *185 capital stock was owned by Warren Browne.

American Box Shook Export Asso. v. Commissioner

4 T.C. 758 · United States Tax Court · Feb 12, 1945

In support of its contention, the petitioner relies principally upon San Joaquin Valley Poultry Producers' Association v. Commissioner, 136 Fed. (2d) 382. … It is apparent from the record also that no amounts were distributable to the members without prior action on the part of the petitioner’s board of directors.