Case law

Northern Natural Gas Co. v. Commissioner

44 T.C. 74 · United States Tax Court · Apr 14, 1965

Northern Natural Gas Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Northern Natural Gas Co. v. Commissioner Docket No. 4372-63 United States Tax Court 44 T.C. 74 ; 1965 U.S. Tax Ct. … Moline Properties, Inc. v. Commissioner , 319 U.S. 436 ; National Carbide Corporation v. Commissioner , 336 U.S. 422 .

Barrios v. Commissioner

29 T.C. 378 · United States Tax Court · Nov 29, 1957

C. 804 (1956); Brown v. Commissioner, 143 F. 2d 468 (C. A. 5, 1944), affirming a Memorandum Opinion of this Court dated August 31, 1943; Gruver v. Commissioner, 142 F. 2d 363 (C. A. 4, 1944), affirming 1 T. … Mauldin, supra, and Brown v. Commissioner, supra.

Frederick Weisman Co. v. Commissioner

97 T.C. 563 · United States Tax Court · Nov 20, 1991

Markham & Brown, Inc. v. United States, 648 F.2d 1043, 1045 (5th Cir. 1981); Richmond, Fredericksburg & Potomac Railroad v. … Jim Walter Corp. v. United States, 498 F.2d 631, 639 (5th Cir. 1974); Markham & Brown, Inc. v. United States, 648 F.2d 1043 (5th Cir. 1981).

MacManus v. Commissioner

8 T.C. 330 · United States Tax Court · Feb 18, 1947

It is upon this grant of authority that the Board relies in concluding that the “administration” (book treatment) of the estate was in consonance with the grantor’s intention. … If it be argued that the principle set forth in United States v. Ryerson, 312 U. S. 260 ; Guggenheim v. Rasquin, 312 U. S. 254 ; and Powers v. Commissioner, 312 U.

Estate of Boyles v. Commissioner

4 T.C. 1092 · United States Tax Court · Apr 3, 1945

Louis Union Trust Co. v. … Similarly, in Brown v.

Enos v. Commissioner

31 T.C. 100 · United States Tax Court · Oct 21, 1958

Commissioner v. LoBue, supra. … Lucas v. Earl, 281 U. S. 111 ; Burnet v. Leininger, 285 U. S. 136 ; Helvering v. Horst, 311 U. S. 112 ; Helvering v. Eubank, 311 U. S. 122 . Our decision in Joseph Kane, 25 T.

Russell Shappy, Jr. & Linda B. Shappy

United States Tax Court · Dec 4, 2023

Lyeth v. … V.

Curtis Inv. Co., LLC v. Comm'r

114 T.C.M. 141 · United States Tax Court · Aug 2, 2017

Petitioners did not pay Brown & Wood directly for the opinion letters; Chenery paid Brown & Wood from fees petitioners paid to Chenery. … See CNT Inv’rs, LLC v. Commissioner, 144 T.C. 161, 231 (2015). 32 Mr. Hahn listed Mr. Ruble, a lawyer at Brown & Wood, as a reference on documents he provided to petitioners. Mr.

Ach v. Commissioner

42 T.C. 114 · United States Tax Court · Apr 15, 1964

Co. v. … Dudley Co., supra; Norden-Ketay Corporation v. Commissioner, 319 F. 2d 902 (C.A. 2), affirming a Memorandum Opinion of this Court; Commissioner v.

Vinson & Elkins v. Commissioner

99 T.C. 9 · United States Tax Court · Jul 14, 1992

Section 7701(a)(35) defines an enrolled actuary as a person who is enrolled by the Joint Board for the Enrollment of Actuaries (joint board) established under ERISA. … Additionally, she has been a member of the pension section council of the Society of Actuaries since 1989, a member of the board of governors of the Society of Actuaries since 1990, a member of the board of directors of the

J.E. Seagram Corp. v. Commissioner

104 T.C. 75 · United States Tax Court · Jan 24, 1995

In Commissioner v. … In Penrod v.

Schoger Foundation v. Commissioner

76 T.C. 380 · United States Tax Court · Feb 24, 1981

All employees are provided room and board, but only the permanent employees receive a salary. … Louis Union Trust Co. v. United States, 374 F.2d 427 (8th Cir. 1967); Steven Bros. Foundation, Inc. v.

Midland Mortg. Co. v. Commissioner

73 T.C. 902 · United States Tax Court · Feb 26, 1980

The legislative history of what are now sections 6212 and 6213 contains the following pertinent language: the taxpayer’s right to claim and sue for refund shall be barred only if he takes the case to the Board [Board of Tax … See Fine v.

Nicolson v. Commissioner

13 T.C. 690 · United States Tax Court · Oct 31, 1949

Nicolson, Petitioner, v. Commissioner of Internal Revenue, Respondent Nicolson v. Commissioner Docket No. 7555 United States Tax Court 13 T.C. 690 ; 1949 U.S. Tax Ct. … All dividends shall be declared, payable then or thereafter, by the Board of Directors out of the surplus net profits of the corporation not, in the opinion of the Board of Directors, required to be retained or used in the

Overland Corp. v. Commissioner

34 T.C. 1001 · United States Tax Court · Sep 16, 1960

United States v. Andrews, 302 U.S. 517 ; United States v. Garbutt Oil Co., 302 U.S. 528 ; United States v. Henry Prentiss & Co., 288 U.S. 73 ; Real Estate Title Co. v. United States, 309 U.S. 13 . … In Commissioner v. S.

Urban Redevelopment Corp. v. Commissioner

34 T.C. 845 · United States Tax Court · Aug 15, 1960

Urban Redevelopment Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Urban Redevelopment Corp. v. Commissioner Docket No. 70412 United States Tax Court 34 T.C. 845 ; 1960 U.S. Tax Ct. … Brown.

Mellon v. Commissioner

12 T.C. 90 · United States Tax Court · Jan 31, 1949

In Groman v. … The Board said in James Oouzens, 11 B. T.

Rutana v. Commissioner

88 T.C. 1329 · United States Tax Court · May 19, 1987

Northcross v. Board of Education of the Memphis City Schools, 611 F.2d at 643 . … See Northcross v. Board of Education of the Memphis City Schools, 611 F.2d 624, 643 (6th Cir. 1979), cert. denied 447 U.S. 911 (1980).

Rudman v. Comm'r

118 T.C. 354 · United States Tax Court · Apr 29, 2002

In years prior to 1994, petitioner was a member of the Chicago Board of Trade (CBOT), and petitioner actively traded U.S. Treasury bond futures contracts for his own account on the trading floor of the CBOT. … In Kovner v. Commissioner, 94 T.C. 893, 906 (1990), for purposes of qualifying losses as ordinary losses under section 108(a) of the Deficit Reduction Act of 1984, Pub.

Ketcham v. Commissioner

2 T.C. 159 · United States Tax Court · Jun 18, 1943

The 1933 income of the second trust had been determined by the Commissioner to be taxable to the husband, but the Board of Tax Appeals, in a proper proceeding brought by Francis V. duPont, Docket No. 86754, held that, since … Ingraham v.