Case law

Brown v. Commissioner

43 T.C.M. 1322 · United States Tax Court · May 5, 1982

BROWN AND ROSALIE BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Brown v. Commissioner Docket No. 9570-79. United States Tax Court T.C. Memo 1982-253 ; 1982 Tax Ct. Memo LEXIS 497 ; 43 T.C.M. … Brown (petitioner) was employed as a surgeon and petitioner Rosalie Brown was employed as a nurse.

Brown v. Comm'r

2007 T.C. Summary Opinion 135 · United States Tax Court · Aug 2, 2007

BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7001-04S. Filed August 2, 2007. Gary S. Brown and Julie A. Brown, pro sese. Alan H. … Brown. Petitioner is an attorney. During all times relevant, he conducted the practice of law as sole proprietorship in the Los Angeles, California, area.

Brown v. Commissioner

56 T.C.M. 1388 · United States Tax Court · Feb 28, 1989

KENNETH AUSTIN BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Brown v. Commissioner Docket No. 16972-87. United States Tax Court T.C. Memo 1989-89 ; 1989 Tax Ct. Memo LEXIS 78 ; 56 T.C.M. … Kenneth Austin Brown, pro se. Ruud L. DuVall, for the respondent.

Brown v. Commissioner

72 T.C.M. 620 · United States Tax Court · Sep 17, 1996

Memo. 1996-416 UNITED STATES TAX COURT LANCE BROWN, Petitioner v. … See Wright v. Commissioner, 84 T.C. 636 (1985); Castillo v. Commissioner, 84 T.C. 405, 409-410 (1985); Curry v. Commissioner, T.C. Memo. 1991-102; Whyte v. Commissioner, T.C.

Hug Co. v. War Contracts Price Adjustment Board

14 T.C. 621 · United States Tax Court · Apr 18, 1950

From the foregoing we think it is clear that Hug not only- controlled the petitioner’s board of directors, but that when they took action which he later desired to disregard he did so without referring the matter back to … Since Hug controlled the meetings of the petitioner’s stockholders, controlled petitioner’s board of directors, and controlled petitioner’s operations and assets to the extent here shown, we conclude that he was in actual

Abramson v. R. F. C. Price Adjustment Board

11 T.C. 1037 · United States Tax Court · Dec 15, 1948

Assn. v. Tankersley, 69 So. 410, 413 ; McCaskey Register Co. v. Lumpkin, 197 So. 640, 641 . … Leahy v. United States, 15 Fed. (2d) 949; Profit v. Seabord Mut. Casualty Co., 28 Fed. Supp. 202, 205; Columbian Nat. Life Ins. Co. v. Rodgers, 93 Fed. (2d) 740.

Sharp v. Commissioner

75 T.C. 21 · United States Tax Court · Oct 6, 1980

Brown J. Sharp (petitioner) was a resident of Lexington, Ky., at the time the petition in this case was filed. He filed his 1975 Federal income tax return with the Internal Revenue Service Center in Memphis, Tenn. … See, e.g., Wilkerson v. Commissioner, supra; Hyde v. Commissioner, 64 T.C. 300 (1975); Dorzback v. Collison, 195 F.2d 69 (3d Cir. 1952).

Cuckler v. Commissioner

39 T.C. 1107 · United States Tax Court · Mar 29, 1963

Helvering v. Lazarus & Co., 308 U.S. 252 . Niceties of title or conveyancing should not hide the tax effects of whole transactions. Cf. Gregory v. Helvering, 293 U.S. 465 ; Griffiths v. … and Cuckler and Brown paid nothing for it.

Moening & Heckmann v. War Contracts Price Adjustment Board

14 T.C. 589 · United States Tax Court · Apr 17, 1950

See Regulations 382.2 (2); Greaves v. War Contracts Price Adjustment Board, 10 T. C. 886 ; Grot Brothers v. Secretary of War, 9 T. C. 495 . His figure for both partners for both businesses aggregates $40,000. … See Continental Chemical & Engineering Supply v. War Contracts Price Adjustment Board, 11 T. C. 45 . See sec. 403 (a) (4) (A).

BROWN v. COMMISSIONER

2004 T.C. Summary Opinion 130 · United States Tax Court · Sep 21, 2004

BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 11482-02S. Filed September 20, 2004. David A. Brown, pro se. Marc L. Caine, for respondent. … Unless otherwise indicated, all subsequent section references are to the Internal * This report is a supplement to Brown v. Commissioner, T.C.

Brown v. Commissioner

71 T.C.M. 1974 · United States Tax Court · Feb 6, 1996

BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6830-94. Filed February 6, 1996. Craig E. and Debbie A. Brown, pro se. … Petitioner's father, Eugene Brown, is the pastor of CHSC. In 1989, petitioner was assigned the position of minister of music by the CHSC board of elders.

Brown v. Commissioner

51 T.C.M. 1171 · United States Tax Court · Jun 12, 1986

BRUCE and JOANNE BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Brown v. Commissioner Docket No. 15981-84. United States Tax Court T.C. Memo 1986-239 ; 1986 Tax Ct. Memo LEXIS 369 ; 51 T.C.M. … Commissioner v. Brown, 380 U.S. 563 (1965) . Generally, a sale of real property is complete upon the earlier of the transfer of legal *405 title or the assumption of the benefits and burdens of ownership. Derr v.

Brown v. Commissioner

28 T.C.M. 1330 · United States Tax Court · Dec 2, 1969

Joe A. and Helen Brown v. Commissioner. Brown v. Commissioner Docket No. 2106-69 SC. United States Tax Court T.C. Memo 1969-257 ; 1969 Tax Ct. Memo LEXIS 40 ; 28 T.C.M. (CCH) 1330 ; T.C.M. … Commissioner v. Gillette Motor Transport, Inc., 364 U.S. 130 , 134 (1960) . Petitioners have not shown that Brown had any interest in the insurance policies themselves. See Commissioner v.

Aircraft Screw Products Co. v. War Contracts Price Adjustment Board

8 T.C. 1037 · United States Tax Court · May 14, 1947

This determination was adopted by respondent, the War Contracts Price Adjustment Board, as its determination. … See John Kelley Co., supra; Commissioner v. O. P. P. Holding Corporation, supra; Commissioner v. Bray Co., 126 Fed. (2d) 612. Respondent has failed to carry its burden.

Brown v. Commissioner

71 T.C.M. 2301 · United States Tax Court · Mar 6, 1996

BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10823-95. Filed March 6, 1996. James E. Brown, pro se. … Pesch v. Commissioner, 78 T.C. 100, 120 (1982); Krieger v. Commissioner, supra; Beer v. Commissioner, T.C. Memo. 1982-735, affd. 733 F.2d 435 (6th Cir. 1984); see also Burnet v.

Leh v. Commissioner

27 T.C. 892 · United States Tax Court · Mar 11, 1957

Commissioner v. Starr Brothers, Inc., 204 F. 2d 673, 674 (C. A. 2). We recognize that controversies in this field have resulted in. some rather fine distinctions. … Hand undertook in the McCue Bros. & Drummond case to distinguish the two lines of cases; in cases such as Starr Brothers, supra, and General Artists Corp. v. Commissioner, 205 F. 2d 360 (C.

Supply Division, Inc. v. War Contracts Price Adjustment Board

9 T.C. 1103 · United States Tax Court · Dec 15, 1947

See also Spaulding v. Douglas Aircraft Co., 154 Fed. (2d) 419; United States v. Lichter, 68 Fed. Supp. 19; affd., 160 Fed. (2d) 329; certiorari granted, 331 U. S. 802 ; United States v. Pownall, 65 Fed. … Nor are the provisions of section 403 (b) a limitation on the Board’s power to renegotiate under section 403 (c). See Spaulding v. Douglas Aircraft Co., supra.

Brown v. Comm'r

86 T.C.M. 347 · United States Tax Court · Sep 9, 2003

BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8368-02L. Filed September 9, 2003. Jerry Arthur Jewett, for petitioner. Michelle M. … Brown, docket No. 8368-02L; Harold V. and Imogene N. Pahl, docket No. 11572-02L; Charles and Teresa Brodman, docket No. 16598-02L.  - 7 - collection, and presented frivolous arguments.

Brown v. Comm'r

85 T.C.M. 1015 · United States Tax Court · Mar 13, 2003

Memo. 2003-73 UNITED STATES TAX COURT JEROME EDWARD BROWN AND MARY L. SMITH BROWN, Petitioners v. … Sego v. Commissioner, 114 T.C. 604, 610 (2000). Based on petitioners’ late-filed 1996 tax return, respondent abated a portion of petitioners’ income tax, additions to tax, and interest for 1996.

Brown v. Commissioner

74 T.C.M. 1449 · United States Tax Court · Dec 23, 1997

BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10823-95. Filed December 23, 1997. James E. Brown, pro se. … See Brown v. Commissioner, T.C. Memo. 1996-100. Issue 1. Period of Limitations Respondent determined a deficiency in petitioner's income tax of $44,086 for 1990.