Case law

World Airways, Inc. v. Commissioner

62 T.C. 786 · United States Tax Court · Sep 18, 1974

Trinity Construction Co. v. United States, 424 F. 2d 302, 305 (C.A. 5, 1970); see also Brown v. Helvering, 291 U.S. 193 (1934); Security Flour Mills Co. v. Commissioner, 321 U.S. 281 (1944). … Brown v. Helvering, supra at 201 .

Acuity, A Mut. Ins. Co., & Subsidiaries v. Comm'r

106 T.C.M. 233 · United States Tax Court · Sep 4, 2013

V. … V.

Keleher v. Commissioner

25 T.C. 1154 · United States Tax Court · Jan 26, 1956

Brown, 7 T. C. 715 . … Maschaur v. Maschaur, 23 App. D. C. 87.

International Inv. Corp. v. Commissioner

11 T.C. 678 · United States Tax Court · Oct 25, 1948

It is well stated in Tri-Lakes Steamship Co. v. … In 1942 the United States Board of Tax Appeals decided the case of Stimson Mill Co., 46 B. T.

Morris Inv. Corp. v. Commissioner

5 T.C. 583 · United States Tax Court · Aug 10, 1945

Disney, Jvdge: The first and principal question here presented has already received no little attention in Lakeside Irrigation Co. v. Commissioner, 128 Fed. (2d) 418, affirming 41 B. T. … A. 892, where it is fully discussed; and in Reddington Co. v. Commissioner, 131 Fed. (2d) 1014, affirming the Board of Tax Appeals.

Short v. Commissioner

35 T.C. 922 · United States Tax Court · Mar 14, 1961

Whitlock v. Alexander, supra; Goodman v. White, supra; Gover v. Malever, 187 N.C. 774 , 122 S.E. 841 . In Goodman v. … In further support of this contention, petitioners rely on Abbott v.

Trinidad Nat'l Bank v. Commissioner

22 T.C.M. 444 · United States Tax Court · Mar 29, 1963

The minutes of a board of directors' meeting at 2 P.M. on July 18, 1955, records the resignation of the old Cuckler and Brown *253 board members and officers and the election of a new Lacy board and officers. … Drybrough v. Commissioner.

MacDonald v. Commissioner

55 T.C. 840 · United States Tax Court · Feb 25, 1971

Marsack's Estate v. Commissioner, supra. … Burnet v. Logan, 283 U.S. 404, 412 (1931).

Burton-Sutton Oil Co. v. Commissioner

3 T.C. 1187 · United States Tax Court · Aug 4, 1944

The decision of the Commissioner and of the Board in this respect is approved. To the same effect are Jones’ Estate v. Commissioner, 127 Fed. (2d) 231, and Moynier v. Welch, 97 Fed. (2d) 471. … While the general rule is as above stated, the Board held in L. B.

Penick v. Commissioner

37 T.C. 999 · United States Tax Court · Feb 27, 1962

Penick, Petitioner, v. Commissioner of Internal Revenue, Respondent Penick v. Commissioner Docket No. 75658 United States Tax Court 37 T.C. 999 ; 1962 U.S. Tax Ct. … Both parties cite and discuss Commissioner v. Duberstein , 363 U.S. 278 .

Harvey v. Commissioner

12 T.C.M. 1358 · United States Tax Court · Nov 30, 1953

Harvey v. Commissioner. Harvey v. Commissioner Docket No. 40991. United States Tax Court 1953 Tax Ct. Memo LEXIS 49 ; 12 T.C.M. (CCH) 1358 ; T.C.M. (RIA) 53376 ; November 30, 1953 *49 1. … Board and by that Board were delivered to petitioner for whom they were designated by Brown-Forman.

Putoma Corp. v. Commissioner

66 T.C. 652 · United States Tax Court · Jun 30, 1976

Article V, section 4 of Pro-Mac’s bylaws provides that the salaries of corporate officers are to be fixed by the board of directors. … Substantially the same decision was made by Pro-Mac’s board of directors in a meeting held the same day.

Kingfisher Cooperative Elevator Asso. v. Commissioner

84 T.C. 600 · United States Tax Court · Apr 2, 1985

Petitioner’s business activities were managed by its board of directors. The board was composed of five members who were elected to staggered 3-year terms by the members at annual membership meetings. … See Lamesa Cooperative Gin v. Commissioner, supra. In Lamesa Cooperative Gin v.

Estate of Leavitt v. Commissioner

90 T.C. 206 · United States Tax Court · Feb 10, 1988

Brown v. Commissioner, 706 F.2d 755 (6th Cir. 1983), affg. T.C. Memo. 1981-608 ; Calcutt v. Commissioner, 84 T.C. 716, 720 (1985). The term “basis,” for purposes of section 1374(c), is defined in section 1012. 7 Borg v. … See also Brown v.

Dunlap & Associates, Inc. v. Commissioner

47 T.C. 542 · United States Tax Court · Feb 28, 1967

See Reef Corporation v. … The case of Helvering v.

Kraus Trust v. Commissioner

6 T.C. 105 · United States Tax Court · Jan 24, 1946

See sec. 115 (g) . *354 Wilcox v. Commissioner , 137 Fed. (2d) 136 ; McGuire v. Commissioner , 84 Fed. (2d) 431 ; certiorari denied, 299 U.S. 591 ; Flanagan v. Helvering , 116 Fed. (2d) 937 ; Rheinstrom v. … A. 866 ; Robinson v. Commissioner , 69 Fed. (2d) 972 ; Brown v. Commissioner , 79 Fed. (2d) 73 ; W. & K. Holding Corporation , 38 B. T. A. 830 ; Bass v. Commissioner , 129 Fed. (2d) 300 ; Smith v.

Harris v. Commissioner

69 T.C.M. 1633 · United States Tax Court · Jan 11, 1995

BROWN HARRIS II, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Harris v. Commissioner Docket No. 11256-92 United States Tax Court T.C. Memo 1995-9 ; 1995 Tax Ct. Memo LEXIS 9 ; 69 T.C.M. … Brown Harris II, pro se. For respondent: Robert M. Fowler .

Rinehart v. Commissioner

18 T.C. 672 · United States Tax Court · Jun 26, 1952

Rinehart, Petitioners, v. Commissioner of Internal Revenue, Respondent Rinehart v. Commissioner Docket No. 30180 United States Tax Court 18 T.C. 672 ; 1952 U.S. Tax Ct. … The petitioner in , was not an employee of *674 Bache who paid a part of the amount which went to the seller when Brown acquired some stock, and the amount paid by Bache could not represent compensation to Brown.

Bihlmaier v. Commissioner

17 T.C. 620 · United States Tax Court · Oct 8, 1951

In Cape May Real Estate Co. v. … See Reading Co. v. Commissioner, 132 F. 2d 306, 310 , affirming a Memorandum Opinion of the Board of Tax Appeals (now this Court).

Battat v. Comm'r

113 T.C.M. 3916 · United States Tax Court · Feb 2, 2017

by the Internal Revenue Service (IRS) of their tax liabilities before payment.5 The Revenue Act of 1924 provided that “[t]here is hereby established a board to be known as the Board of Tax Appeals” and “[t]he Board shall … In 1926 Congress made various statutory changes with respect to the Board of Tax Appeals, but the statute continued to provide that the Board of Tax Appeals is “an independent agency in the Executive Branch of the Government