Case law

Rockford Screw Products Co. v. Commissioner

21 T.C. 834 · United States Tax Court · Feb 26, 1954

REVIEW OP ABNORMALITIES BY BOARD OP TAX APPEALS. … REVIEW OF ABNORMALITIES BY BOARD OF TAX APPEALS.

Sandra M. Conard v. Commissioner

United States Tax Court · Mar 10, 2020

McDonald v. Board of Election Com’rs of Chicago, 394 U.S. 802, 809 (1969). Estate of Kunze v. Commissioner, 233 F.3d 948, 954 (7th Cir. 2000), aff’g T.C. … FCC, 721 F.2d 667, 670 (9th Cir. 1983), and Brown v. Sibley, 650 F.2d 760, 765- 766 (5th Cir. 1981)). Accordingly, section 72(t) as applied to Ms. Conard is subject to the rational-basis test.

Abingdon Potteries, Inc. v. Commissioner

19 T.C. 23 · United States Tax Court · Oct 10, 1952

True, petitioner’s board of directors had resolved on December 28,1944, to create such a trust, presumably to be patterned after a specimen instrument submitted to it, and had authorized a contribution of not to exceed $25,000 … Tavannes Watch Co. v. Commissioner, 176 F. 2d 211 (C. A. 2), reversing 10 T. C. 544 , also relied upon by petitioner, did not turn upon the issue decided herein. 1 Reviewed by the Court.

Doty v. Commissioner

81 T.C. 652 · United States Tax Court · Sep 28, 1983

Winn v. Winn, 143 Cal. App. 2d 184 , 299 P.2d 721, 725 (1956); In re Marriage of House, 50 Cal. App. 3d 578 , 123 Cal. Rptr. 451 (1975). Similarly, in In re Marriage of Brown, 15 Cal. 3d 838 , 126 Cal. … In Robida v.

Athens Roller Mills v. Commissioner

4 T.C. 303 · United States Tax Court · Nov 13, 1944

Athens Roller Mills, Petitioner, v. Commissioner of Internal Revenue, Respondent Athens Roller Mills v. Commissioner Docket No. 112562 United States Tax Court 4 T.C. 303 ; 1944 U.S. Tax Ct. … On April 28, 1942, the Board of Tax Appeals promulgated its findings of fact and opinion in Athens Roller Mills, Inc. v. Commissioner , Docket 99055 ( 46 B. T.

Pope & Talbot, Inc. v. Commissioner

104 T.C. 574 · United States Tax Court · May 8, 1995

Co. v. Commissioner, 101 T.C. 294, 295 (1993); Shiosaki v. Commissioner, 61 T.C. 861, 862 (1974). … The board of directors that recommended the plan owed a fiduciary duty to act in the best interests of the shareholders. Revlon, Inc. v. MacAndrews & Forbes Holdings, Inc., 506 A.2d 173, 179 (Del. 1986).

Coast Carton Co. v. Commissioner

10 T.C. 894 · United States Tax Court · May 18, 1948

the Board of Tax Appeals for the year 1923. … Cromwell v. County of Sac, supra, 353 . And see Russell v. Place, 94 U. S. 606 ; Southern Pacific R. Co. v. United States, 168 U. S. 1, 48 ; Mercoid Corp. v. Mid-Continent Co., 320 U. S. 661, 671 .

Weinroth v. Commissioner

33 T.C. 58 · United States Tax Court · Oct 19, 1959

Weinroth & Eva Weinroth, Petitioners, v. Commissioner of Internal Revenue, Respondent Weinroth v. Commissioner Docket No. 67104 United States Tax Court 33 T.C. 58 ; 1959 U.S. Tax Ct. … Petitioner was paid at a yearly rate by the board of education to teach school.

Tucker v. Comm'r

114 T.C.M. 326 · United States Tax Court · Sep 18, 2017

Ruble when he was preparing the two Brown & Wood opinions. The two Brown & Wood opinions concluded Mr. … The board of directors had advised Mr. Tucker that if he did not resign, he would be fired.

American-LaFrance v. Commissioner

18 T.C.M. 447 · United States Tax Court · May 19, 1959

American-LaFrance-Foamite Corporation v. Commissioner. American-LaFrance v. Commissioner Docket No. 62520. United States Tax Court T.C. Memo 1959-101 ; 1959 Tax Ct. Memo LEXIS 148 ; 18 T.C.M. … Brown and William Nardo. On February 21, 1947, the board of directors of I.M.I. elected Edward E. O'Neill, president, and Clarence A. Pettyjohn, secretary and treasurer of I.M.I.

Miller v. Commissioner

39 T.C. 940 · United States Tax Court · Mar 20, 1963

On July 19, 1953, the Supreme Court of the State of Minnesota issued its opinion affirming the Board of Tax Appeals of the State of Minnesota (Miller’s Estate v. Commissioner of Taxation, 59 N.W. 2d 925 (Minn. 1953)). … of the Board of Tax Appeals of the State of Minnesota.

Park Sherman Co. v. United States

29 T.C. 175 · United States Tax Court · Oct 30, 1957

Neither case involves this point, Glenield being-concerned with fiscal years of less than 12 months, see also Callahan v. War Contracts Price Adjst. Board, 13 T. … were determined by the Board.

Martin Weiner Corp. v. Commissioner

26 T.C. 128 · United States Tax Court · Apr 20, 1956

Tucker v. Alexander, 275 U. S. 228 ; United States v. Memphis Cotton Oil Co., 288 U. S. 62 ; United States v. Humble Oil & Refining Co., (C. A. 5) 69 F. 2d 214 ; United States v. Garbutt Oil Co., 302 U. … S. 528 ; United States v. Kales, 314 U. S. 186 ; Angelus Milling Co. v. Commissioner, supra. In United States v.

Estate of Proctor v. Commissioner

1 T.C.M. 713 · United States Tax Court · Feb 9, 1943

Brown and Henry Breckinridge, Executors v. Commissioner. Estate of Proctor v. Commissioner Docket No. 109057. United States Tax Court 1943 Tax Ct. Memo LEXIS 459 ; 1 T.C.M. (CCH) 713 ; T.C.M.

Palmer v. Commissioner

62 T.C. 684 · United States Tax Court · Aug 27, 1974

Prior to September 1,1966, he was president of the college, president of the corporation, and a member of the latter’s board of directors. … In addition, the board of directors and the trustees were authorized to effectuate the redemption.

Cox v. Commissioner

56 T.C. 1270 · United States Tax Court · Sep 13, 1971

See, e.g., Peterson v. Swanson, 223 N.W. 287 (Minn. 1929); Watson v. Goldstein, 222 N.W. 509 (Minn. 1928). … Neiderkrome v. Commissioner, 266 F. 2d 238 (C.A. 9, 1958); Holsey v. Commissioner, 258 F. 2d 865 (C.A. 3, 1958).

Wilmont Fleming Engineering Co. v. Commissioner

65 T.C. 847 · United States Tax Court · Jan 29, 1976

Throndson v. Commissioner, 457 F. 2d 1022 (9th Cir. 1972). … Maddock, 16 T.C. 324 (1951); In Re Brown, 242 N.Y. 1 , 150 N.E. 581 (1926), we find that no goodwill was sold by decedent and Wilmot.

Frank M. Hill Machine Co. v. Stimson

4 T.C. 922 · United States Tax Court · Mar 2, 1945

Hill Machine Company, Petitioner, v. Henry L. Stimson, Secretary of War, Respondent Frank M. Hill Machine Co. v. Stimson Docket No. 82 R. United States Tax Court 4 T.C. 922 ; 1945 U.S. Tax Ct. … The Board was not in existence *924 prior to the 1943 amendment to the Renegotiation Act, but was created by that amendment.

Bruner v. Commissioner

3 T.C. 1051 · United States Tax Court · Jul 4, 1944

Freuler v. Helvering, 291 U. S. 35 . … In In re Brown’s Estate, 190 Pa.

Wiegand v. Commissioner

14 T.C. 136 · United States Tax Court · Jan 31, 1950

Koshland v. Helvering, 298 U. S. 441 ; Helvering v. Gowran, 302 U. S. 238 ; and Helvering v. Pfeiffer, 302 U. S. 247 . When the decisions were at that stage, Helvering v. Sprouse and Strassburger v. … Koshland v. Helvering, supra; Helvering v. Gowran, supra; and Helvering v. Pfeiffer, supra.