Case law

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).

New York Trust Co. v. Commissioner

26 T.C. 257 · United States Tax Court · May 11, 1956

A. 33; Continental Oil Co. v. Helvering, 100 F. 2d 101, 110 (C. A., D. C.). … Hulbert v. Commissioner, 296 U. S. 300, 305-308 .

Findlay v. Commissioner

39 T.C. 580 · United States Tax Court · Dec 27, 1962

In Commissioner v. … Commissioner v. Duberstein, supra.

Wilputte Coke Oven Corp. v. Commissioner

10 T.C. 435 · United States Tax Court · Mar 16, 1948

This determination was sustained by the Board of Tax Appeals and by the Circuit Court. … Chattanooga Savings Bank v. Brewer, 17 Fed. (2d) 79; certiorari denied, 274 U. S. 751 ; Christopher v. Burnet, 55 Fed. (2d) 527, affirming 13 B. T. A. 729; Anketell Lumber & Coal Co. v. United States, 1 Fed.

Virginia Metal Products, Inc. v. Commissioner

33 T.C. 788 · United States Tax Court · Jan 29, 1960

However, the respondent calls our attention to the case of Libson Shops v. … . & Container Corp. v. Commissioner, 14 T.C. 842 ; W A G E, Inc. v. Commissioner, 19 T.C. 249 .

Ford-Iroquois FS, Inc. v. Commissioner

74 T.C. 1213 · United States Tax Court · Sep 9, 1980

Union Equity Cooperative Exchange v. Commissioner, 58 T.C. 397, 403 (1972), affd. 481 F.2d 812 (10th Cir. 1973). See also Smith & Wiggins Gin, Inc. v. … Frost v. Corporation Commission, 278 U.S. 515, 546 (1929).

Borax v. Commissioner

30 T.C. 817 · United States Tax Court · Jun 30, 1958

Brown, 7 T. C. 715 . … In Smith v. Commissioner, (C.

Rose v. Commissioner

56 T.C. 185 · United States Tax Court · Apr 27, 1971

This instrument is executed by the parties hereto, the day and *148 year first above written in four (4) counterparts, any one of which may be deemed an original: Berta Rose Brown J. O. Brown Ollie G. Rose Margaret R. … Rose, Deceased, Berta Rose Brown, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent. ↩ 1. All references by section are to the Internal Revenue Code of 1954 unless otherwise stated. ↩ 2.

International Proprietaries, Inc. v. Commissioner

18 T.C. 133 · United States Tax Court · Apr 28, 1952

. & Co. v. Commissioner, 124 F. 2d 606, 609 ; Stranahan v. Commissioner, 42 F. 2d 729 , certiorari denied 283 U. S. 822 . The deduction claimed by the petitioner was for debts of its two wholly-owned subsidiaries. … In affirming our decision, the court said: We agree with the Board that the taxpayer must eliminate the debt as an asset on its books in order to comply with the statutory requirements of charge-off.

National Bank of Commerce v. Commissioner

12 T.C. 717 · United States Tax Court · May 6, 1949

Commissioner, supra, though it followed a somewhat different line of reasoning than that used by the Board of Tax Appeals. In Commissioner v. Sunnen, 33 U. … Tait v. Western Md. R. Co., 289 U.

Knott v. Commissioner

67 T.C. 681 · United States Tax Court · Jan 18, 1977

Knott served on the committees and boards of the following charitable and civic organizations: Archdiocesan Finance Committee. .Committee member Archdiocesan Insurance Committee. .Committee member Baltimore Airport Board. … On brief, respondent argues that "gift” is properly defined by Edson v. Lucas, 40 F.2d 398, 404 (8th Cir. 1930), and that petitioners fail to meet the criteria outlined therein. Edson 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.

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.

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.

Kirk v. Commissioner

51 T.C. 66 · United States Tax Court · Oct 17, 1968

Kirk, Petitioners v. Commissioner of Internal Revenue, Respondent Kirk v. Commissioner Docket No. 6333-66 United States Tax Court 51 T.C. 66 ; 1968 U.S. Tax Ct. … The board shall be incorporated. *71 para. 1517. Board members and executives of the board shall speak and act in the true freedom of forgiven men.

Estate of Amick v. Commissioner

67 T.C. 924 · United States Tax Court · Mar 10, 1977

The rationale of the revenue ruling is strongly supported by Wilber National Bank, Executor, 17 B.T.A. 654 (1929), a Board-reviewed case, with facts very similar to the facts in this case. … Gund’s Estate v. Commissioner, 113 F.2d 61 (6th Cir. 1940), affg. a Memorandum Opinion of this Court, cert. denied 311 U.S. 696 (1940); Child v. United States, 540 F.2d 579 (2d Cir. 1976).

Your Health Club, Inc. v. Commissioner

4 T.C. 385 · United States Tax Court · Nov 28, 1944

See Clary Sewer Life Assn. v. Commissioner, 139 Fed. (2d) 130, affirming 1 T. C. 529 ; South Dade Farms, Inc. v. Commissioner, 138 Fed. (2d) 818. See also Brown v. Helvering, 291 U. S. 193 . … Security Flour Mills Co. v. Commissioner, supra), petitioner makes no claim under that provision; nor has it complied with the requirements of section 19.43-1 of Regulations 103, 1 implementing section 43 (Cassatt v.

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.

Haas v. United States

23 T.C. 892 · United States Tax Court · Feb 18, 1955

The War Contracts Price Adjustment Board determined that the admission of the new partners caused the dissolution of the partnership upon the admission of each. … Hoffman v. United States, 23 T. C. 569 . With respect to Haas Mold Company #2, the story is different.

Bennett v. Commissioner

58 T.C. 381 · United States Tax Court · May 30, 1972

The court, in Wall, distinguished Fox v. … See, e.g., Sullivan v. United States, 363 F. 2d 724 (C.A. 8, 1966); Woodworth v. Commissioner, 218 F. 2d 719 (C.A. 6, 1935), affirming a Memorandum Opinion of this Court; Lowenthal v.