Case law

Fuqua v. Commissioner

27 T.C. 909 · United States Tax Court · Mar 11, 1957

Brown, 7 T. C. 715 . … Smith v. Commissioner, 168 F. 2d 446 ; Robert L. Daine, 9 T. C. 47 , affd. 168 F. 2d 449 ; and John B. Keleher, 25 T. C. 1154 .

Miller v. Commissioner

65 T.C. 612 · United States Tax Court · Dec 22, 1975

The board of directors (board), which managed the business of the cooperative, was required to approve all new members. … See Welch v. Helvering, 290 U.S. 111 (1933); Kentucky Utilities Co. v. Glenn, 394 F. 2d 631 (6th Cir. 1968).

DeWitt v. Commissioner

30 T.C. 1 · United States Tax Court · Apr 9, 1958

The next day DeWitt notified the Dealer Delations Board that he was withdrawing his appeal. These letters were occasioned by the sale of the business to Goddard. … In Commissioner v. Court Holding Co., 324 U.

Whitaker v. Commissioner

24 T.C. 750 · United States Tax Court · Jul 26, 1955

Whitaker, Petitioners, v. Commissioner of Internal Revenue, Respondent Whitaker v. Commissioner Docket No. 52093 United States Tax Court 24 T.C. 750 ; 1955 U.S. Tax Ct. … This sum consists of board and lodging expenses in the amount of $ 128.80 incurred at Minneapolis and board and lodging expenses in the amount of $ 1,374.25 incurred at Thule.

Blasdel v. Commissioner

58 T.C. 1014 · United States Tax Court · Sep 25, 1972

Bank v. Commissioner, 141 F. 2d 422, 424 (C.A. 5, 1944); Howe v. … In Hessenbruch v.

Browne v. Commissioner

73 T.C. 723 · United States Tax Court · Jan 22, 1980

Alice Pauline Browne, Petitioner v. Commissioner of Internal Revenue, Respondent Browne v. Commissioner Docket No. 4466-77 United States Tax Court 73 T.C. 723 ; 1980 U.S. Tax Ct. … Cohan v. Commissioner , 39 F.2d 540 (2d Cir. 1930) . 4. Petitioner is not entitled to a trial by jury in the Tax Court. Alice Pauline Browne, pro se. M. Celeste Pickron , for the respondent. Irwin , Judge .

J. G. Boswell Co. v. Commissioner

34 T.C. 539 · United States Tax Court · Jun 23, 1960

Boswell Company, Petitioner, v. Commissioner of Internal Revenue, Respondent. J. G. Boswell Company (successor by merger to Tulare Lake Land Company), Petitioner, v. Commissioner of Internal Revenue, Respondent J. G. … The sump area, which includes the Brown, Dunn, and Section 3 ranches, became dry about June 24, 1953.

Barrett v. Commissioner

58 T.C. 284 · United States Tax Court · May 11, 1972

In Higgins v. … See also White’s Will v. Commissioner, 119 F. 2d 619, 621 (C.A. 3, 1940); McDowell v. Ribicoff, supra. Petitioner is clearly not engaged in offering his services as an adviser or consultant to others.

Sherman v. Commissioner

16 T.C. 332 · United States Tax Court · Feb 15, 1951

Commissioner v. Flowers, 326 U. S. 465 ; Mort L. Bixler, 5 B. T. A. 1181, 1184. … Brown, 13 B. T. A. 832; Joseph W. Powell, 34 B. T. A. 655, affd., 94 Fed. (2d) 483 (CA-1). This case is unlike S. M. R. O'Hara, 6 T.

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.

Husted v. Commissioner

47 T.C. 664 · United States Tax Court · Mar 29, 1967

The petitioner was elected to the board on March 17,1959. … Later, however, in Commissioner v.

Gundanna v. Comm'r

136 T.C. 151 · United States Tax Court · Feb 14, 2011

See Wayne Bolt & Nut Co. v. … Monahan v. Commissioner, 109 T.C. 235, 240 (1997) (quoting Hang v. Commissioner, 95 T.C. 74, 80 (1990)).

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.

Boettiger v. Commissioner

31 T.C. 477 · United States Tax Court · Nov 28, 1958

Brown, 7 T. … In Dean V. Fuqua, 27 T.

Nat'l Elec. Welding Machs. Co. v. Stimson

10 T.C. 49 · United States Tax Court · Jan 13, 1948

Referring to Perry v. United States, 294 U. … Helvering v. Stockholms, Enskilda Bank, 293 U. S. 84 .

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 .

Whitman v. Commissioner

12 T.C. 324 · United States Tax Court · Mar 9, 1949

Smart v. Commissioner, 152 Fed. (2d) 333, 335; Lindstrom v. Commissioner, 149 Fed. (2d) 344, 346. … Lucilla de V. Whitman,” with no further designation.

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 .

Bear Mill Mfg. Co. v. Commissioner

15 T.C. 703 · United States Tax Court · Nov 24, 1950

The Board of Tax Appeals held that the deceased stockholder did not intend to make a gift to the taxpayer, but that he intended to pay the old debt, although he was not legally required so to do, and chose the medium of a … On that point we said: In the case of Zevalo v. Reeves, 227 U. S. 625 , the Supreme Court held that a discharge in bankruptcy destroys the remedy but not the indebtedness.

Arkansas Best Corp. v. Commissioner

83 T.C. 640 · United States Tax Court · Oct 29, 1984

Young served as chairman of the board of Arkansas Best. … Higgins v. Commissioner, 312 U.S. 212 (1941). See Whipple v. Commissioner, 373 U.S. 193, 202-203 (1963); Bodzy v. Commissioner, 321 F.2d 331 (5th Cir. 1963); United States v. Byck, 325 F.2d 551 (5th Cir. 1963); Deely v.