Case law

Latendresse v. Commissioner

26 T.C. 318 · United States Tax Court · May 25, 1956

See also Estate of Edgar V. O'Daniel, 10 T. C. 631 , affd. 173 F. 2d 966 . … Commissioner of Internal Revenue v. Thompson, 3 Cir., 222 F. 2d 893, 895 ; Colonial Fabrics, Inc. v. Commissioner of Internal Revenue, 2 Cir., 202 F. 2d 105, 107 .

Estate of Hutchinson v. Commissioner

51 T.C. 874 · United States Tax Court · Feb 27, 1969

In Merchant's Bank v. … In Henslee v.

Lamesa Cooperative Gin v. Commissioner

78 T.C. 894 · United States Tax Court · Jun 8, 1982

In Farm Service Cooperative v. … In Ford-Iroquois FS, Inc. v. Commissioner, supra, and Farm Service Cooperative v.

Sabelis v. Commissioner

37 T.C. 1058 · United States Tax Court · Mar 9, 1962

horses_ $205. 00 Expenses: Labor_$870. 00 Feed_ 887. 86 Depreciation - 40.00 Shoeing_ 139. 92 Veterinary_ 95. 50 Miscellaneous _ 5.35 - 2,038.63 Loss _ (1,833.63) 1957 Income: Boarding horses_ $603. 30 Biding lessons- 192 … We think, however, that this is a proper case for applying the principles of Cohan v. Commissioner, 39 F. 2d 540 (C.A. 2, 1930).

Gleason Works v. Commissioner

58 T.C. 464 · United States Tax Court · Jun 15, 1972

Compare Wisconsin Gas Co. v. United States, 322 U.S. 526 (1944). Tire next event after Biddle was the decision of the Board of Tax Appeals in Crowford Music Corporation, 40 B.T.A. 284 (1939). … See Biddle v. Commissioner, 302 U.S. at 576, fn. 3 . Compare Wisconsin Gas Co. v.

Phillips Petroleum Co. v. Commissioner

104 T.C. 256 · United States Tax Court · Mar 9, 1995

, and the Special Board of Appeal. … McGuire v. Commissioner, 44 T.C. 801, 808 (1965); Avery v. Commissioner, 3 T.C. 963, 973 (1944).

Slaymaker Lock Co. v. Commissioner

18 T.C. 1001 · United States Tax Court · Sep 15, 1952

New Colonial Ice Co. v. Helvering, 293 U. S. 435 ; Lake v. Commissioner, 148 F. 2d 898 , certiorari denied 326 U. S. 732 . … Deputy v. DuPont, 308 U. S. 488 . As observed by the Supreme Court in the case of Welch v. Helvering, 290 U.

Greenvine Corp. v. Commissioner

40 T.C. 926 · United States Tax Court · Sep 6, 1963

Long Poultry Farms v. … See and compare Massey v. Tomlinson, 308 F. 2d 168 (C.A. 5, 1962),

Wisconsin Nipple & Fabricating Corp. v. Commissioner

67 T.C. 490 · United States Tax Court · Dec 16, 1976

Cornell-Young Co. v. … In Time Oil Co. v.

Allen v. Commissioner

34 T.C.M. 242 · United States Tax Court · Feb 27, 1975

No one involved had any doubts concerning the Board's authority to do so. … In Rude v.

Estate of Morgens v. Comm'r

133 T.C. 402 · United States Tax Court · Dec 21, 2009

The estate also relies on Brown v. United States, 329 F.3d 664 (9th Cir. 2003). In Brown the husband’s estate was his separate property, and the wife had no money of her own. Id. at 667 . … The estate’s reliance on Brown is misplaced.

Grogan Mfg. Co. v. Commissioner

22 T.C. 161 · United States Tax Court · Apr 28, 1954

thousand board feet as “1941 cost of timber used” and $3.25 per thousand as “1942 cost of timber used.” … established either the quantity of such growth or the amount of its income in the taxable years which resulted therefrom, and any determination of such amounts by us would of necessity be after the manner indicated in Cohan v.

Leatherstocking 1983 P'ship v. Comm'r

92 T.C.M. 106 · United States Tax Court · Aug 14, 2006

BROWN, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2753-98. Filed August 14, 2006. Richard J. … Madison Recycling Associates v.

Blount v. Commissioner

51 T.C. 1023 · United States Tax Court · Mar 26, 1969

On March 12, 1960, the company’s stockholders elected a new board of directors, comprised of the members of the old board plus H. J. Hoit. Howard was elected chairman of the board. … Bradbury v. Commissioner, 298 F. 2d 111, 116 (C.A. 1, 1962).

General Lead Batteries Co. v. Commissioner

20 T.C. 685 · United States Tax Court · Jun 29, 1953

(d) Overpayment Found by Board. — * * * No * * * credit or refund shall be made of any portion of the tax unless the Board determines as part of its decision (1) That such portion was paid * * * within two years before * … S. 299 ; Sherwood Bros. v. District of Columbia, 72 App. D. C. 155, 113 F. 2d 162 ; Wilson v. Southern R. Co., 147 F. 2d 165 . Contra: Johnson v. Meyers, 54 F. 417 ; Meyer v. Hot Springs Imp.

Scifo v. Commissioner

68 T.C. 714 · United States Tax Court · Aug 23, 1977

United States v. Generes, 405 U.S. 93 (1972); Shinefeld v. Commissioner, 65 T.C. 1092 (1976). … Boehm v. Commissioner, 326 U.S. 287 (1945). As stated in Morton v.

Masterson v. Commissioner

1 T.C. 315 · United States Tax Court · Dec 22, 1942

The proceedings in that case were tendered to the Court of Appeals upon its review of the Board’s decision. … Jeter v. Hewitt, 22 How. (U. S.) 352, 364.

Greene v. Commissioner

85 T.C. 1024 · United States Tax Court · Dec 24, 1985

Dixon v. United States, 381 U.S. 68, 73 (1965); Stubbs, Overbeck & Associates v. United States, 445 F.2d 1142, 1146-1147 (5th Cir. 1971). … Although the Court is not bound by the stipulation of the parties as to matters of law, see King v.

Lichterman v. Commissioner

37 T.C. 586 · United States Tax Court · Dec 29, 1961

The Bilder case was appealed to the Court of Appeals for the Third Circuit, which held (Commissioner v. … Commissioner v. South Texas Lumber Co., 333 U.S. 496 .

Church of Transfiguring Spirit, Inc. v. Commissioner

76 T.C. 1 · United States Tax Court · Jan 5, 1981

The only members of the petitioner are the members of the board of directors. Mr. Thayer and Mrs. … See Southern Church of Universal Brotherhood Assembled, Inc. v. Commissioner, 74 T.C. 1223 (1980); Basic Bible Church v. Commissioner, supra; Unitary Mission Church v.