Case law

JENKINS v. COMMISSIONER

102 T.C. 550 · United States Tax Court · Apr 6, 1994

Sente Investment Club Partnership v. Commissioner, 95 T.C. 243 (1990). … See Miller v. Commissioner, 52 T.C. 752 (1969) (guaranteed payments were excludable from gross income under sec. 911). But see Kampel v.

Calhoun v. Commissioner

27 T.C. 115 · United States Tax Court · Oct 25, 1956

Brown, Esq., attorney of record; that the Court has jurisdiction herein and that this decree is entered within the time required by law; and that a divorce ought to be granted to the plaintiff upon the statutory grounds of … See also Commissioner v. Ostler, (C A. 9, 1956) 237 F. 2d 501 ; and United States v. Holcomb, (C. A. 9, 1956) 237 F.2d 502 .

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.

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).

Palomar Laundry v. Commissioner

7 T.C. 1300 · United States Tax Court · Dec 9, 1946

.” * * * The First Circuit in affirming the Board, said at page 76: We agree with the reasoning of the Board of Tax Appeals by which it reaches the conclusion that invested capital cannot be increased by commissions paid … La Belle Iron Works v. United States, 256 U. S. 377 . See also Finance Corporation of New England, 16 B. T. A. 763.

Albright v. Commissioner

42 T.C. 643 · United States Tax Court · Jun 25, 1964

Albright, Jr., Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent Albright v. Commissioner Docket No. 91041 United States Tax Court 42 T.C. 643 ; 1964 U.S. Tax Ct. … Dividend equivalents contingently credited shall be payable or distributable in the manner *90 and under the same conditions and contingencies as described under Section V of this Plan for deferred compensation.

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.

Bell Electric Co. v. Commissioner

45 T.C. 158 · United States Tax Court · Nov 19, 1965

In American Automobile Association v. United States, 367 U.S. 687 , and Schlude v. … Brown v. Helvering, 291 U.S. 193, 201-202 . And this is so regardless of whether its obligation is direct or otherwise. Petitioners rely in part upon Bressner Radio, Inc. v.

Bergan v. Commissioner

1 T.C. 543 · United States Tax Court · Feb 9, 1943

Petitioner primarily contends as to this property that Miss Bergan never at any time made a transfer; that she had renounced her rights as distributee; and that upon the authority of Brown v. … Johnson’s estate, the cases of Brown v. Routzahn, In re Wolfe’s Estate, and In re Clarkson’s Estate, all supra,, relied upon by petitioner in support of her primary contention, have no application here.

Reilly Oil Co. v. Commissioner

13 T.C. 919 · United States Tax Court · Dec 15, 1949

Reilly Oil Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Reilly Oil Co. v. Commissioner Docket No. 19521 United States Tax Court 13 T.C. 919 ; 1949 U.S. Tax Ct. … In Toklan Royalty Corporation v. Jones , 58 Fed.

Produce Reporter Co. v. Commissioner

18 T.C. 69 · United States Tax Court · Apr 10, 1952

Produce Reporter Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Produce Reporter Co. v. Commissioner Docket No. 24044 United States Tax Court 18 T.C. 69 ; 1952 U.S. Tax Ct. … Inc. v. Commissioner, 2 Cir., 176 Fed. (2d) 211 .

Estate of Ratcliffe v. Commissioner

63 T.C.M. 3068 · United States Tax Court · May 27, 1992

RATCLIFFE, JR., EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Estate of Ratcliffe v. Commissioner Docket No. 3464-90 United States Tax Court T.C. Memo 1992-305 ; 1992 Tax Ct. … Brown's value more persuasive. Buffalo Tool & Die Mfg. Co. v. Commissioner , 74 T.C. 441 (1980) . An accurate value of Tract III must reflect the considerable cost of extending a sewer line to the property.

Gagne v. Commissioner

16 T.C. 498 · United States Tax Court · Feb 28, 1951

Thereupon, the board of trustees passed a resolution accepting the gift and appointed Joseph P. McKeehan as the board's member to act with petitioner and Dr. … Copland v. Commissioner, supra ; Edson v. Lucas , 40 Fed. (2d) 398 ; Jacob v. Commissioner , 139 Fed. (2d) 277 ; Steele's Mills , 4 B. T. A. 960 .

J. M. Turner & Co. v. Commissioner

26 T.C. 795 · United States Tax Court · Jun 29, 1956

Halliburton v. Commissioner, (C. A. 9) 78 F. 2d 265 . … There is no indication, either in the minutes of petitioner’s board of directors or on the books of either petitioner or the proprietorship, of any such goodwill having been transferred, acquired, or held.

Zilkha & Sons, Inc. v. Commissioner

52 T.C. 607 · United States Tax Court · Jul 2, 1969

Milwaukee & Suburban Transport Corporation v. Commissioner, 283 F. 2d 279, 283 (C.A. 7, 1960), reversed on other grounds 367 U.S. 906 (1961); John Wanamaker Philadelphia v. … Parisian, Inc. v. Commissioner, 131 F. 2d 394, 395 (C.A. 5, 1942).

Morris Investment 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.

Benak v. Commissioner

77 T.C. 1213 · United States Tax Court · Dec 7, 1981

At such meeting, the board resolved to redeem the stock of the petitioners and Mr. Hulse at the rate of $1,000 per share. … In Whipple v.

Summitt v. Commissioner

134 T.C. 248 · United States Tax Court · May 20, 2010

) SUMMITT v. … V.

Dean v. Commissioner

10 T.C. 19 · United States Tax Court · Jan 8, 1948

S. 737 ; Bazley v. Commissioner, 331 U. S. 737 ; and Heady v. Commissioner, 162 Fed. (2d) 699. In the Bazley case the taxpayer and his wife owned all of the capital stock except one qualifying share. … The Adams case in its legal aspects was similar to the Bazley cas In Heady v.

Hyplains Dressed Beef, Inc. v. Commissioner

56 T.C. 119 · United States Tax Court · Apr 21, 1971

During the calendar years 1963, 1964, and 1965, the petitioner’s officers and board of directors were Samuel V. Davis, president; Thomas P. Shirley, vice president; Arthur J. Ebener, secretary-treasurer; H. M. … During the years 1963, 1964, and 1965, petitioner’s officers owned interests in partnerships as follows: Partnership Sam V. Davis Thomas P. Shirley Arthur J.