Case law

Young v. Comm'r

29 T.C. 850 · United States Tax Court · Feb 17, 1958

Brown, Jr., Esq ., for the petitioners. Edward L. Newberger, Esq ., for the respondent. Train , Judge . … Such report and claims shall be submitted to a Board of Arbitration to be selected in the manner provided for in Paragraph XIV hereof which Board shall determine whether such compensation shall be paid, and if so, the total

Farmers Cooperative Co. v. Commissioner

85 T.C. 601 · United States Tax Court · Oct 24, 1985

West Central Cooperative v. United States, supra. … Petitioners argue that Co-Operative Grain & Supply Co. v. Commissioner, supra, and Petaluma Co-Operative Creamery v.

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.

Central Foundry Co. v. Commissioner

49 T.C. 234 · United States Tax Court · Dec 18, 1967

Graham v. Commissioner , 326 F. 2d 878 , 880 (C.A. 4), reversing 40 T.C. 14 ; Surasky v. … In Steinberg v. Adams , 90 F.

Pahl v. Commissioner

67 T.C. 286 · United States Tax Court · Nov 22, 1976

In United States v. … Blum v. Helvering, 74 F.2d 482 (C.A. D.C. 1934), certiorari denied 295 U.S. 732 (1935); Anderson v. Bowers, 77 F.Supp. 980 (E.D.

Larson v. Commissioner

66 T.C. 159 · United States Tax Court · Apr 27, 1976

In Outlaw v. … In Zuckman v.

TSR, Inc. v. Commissioner

96 T.C. 903 · United States Tax Court · Jun 25, 1991

See Commissioner v. Brown, 380 U.S. 563, 571 (1965). … For example, see Regan v. Wald, 468 U.S. 222, 238 (1984).

Van Zandt v. Commissioner

40 T.C. 824 · United States Tax Court · Aug 8, 1963

He relies on four decisions: Skemp v. Commissioner, 168 F. 2d 598 (C.A. 7, 1948), reversing 8 T.C. 415 (1947); Brown v. Commissioner, 180 F. 2d 926 (C.A. 3, 1950), reversing 12 T.C. 1095 (1949); Albert T. … See Gregory v. Helvering, 293 U.S. 465 (1935); W. H. Armston Co. v. Commissioner, supra; Unger v. Campbell, supra; and Hall v. United States, 208 F. Supp. 584 (N.D.N.Y.1962).

Natural Gasoline Corp. v. Commissioner

21 T.C. 439 · United States Tax Court · Dec 31, 1953

Natural Gasoline Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Natural Gasoline Corp. v. Commissioner Docket No. 41891 United States Tax Court 21 T.C. 439 ; 1953 U.S. Tax Ct. … Apart from the fact that the testimony offered was that of a witness who was not then a member of the board of directors and was not shown to have been present at the board meeting at which the dividend was declared, we cannot

Luckenbach Steamship Co. v. Commissioner

9 T.C. 662 · United States Tax Court · Oct 13, 1947

Cartridge Co. v. United States, 284 U. S. 511 . To the same effect see Patrick McGuirl, Inc. v. Commissioner, 74 Fed. (2d) 729; certiorari denied, 295 U. S. 748 . … The respondent relies in particular upon Continental Tie & Lumber Co. v. Burnet, 286 U. S. 290 ; Automobile Insurance Co. v. Commissioner, 72 Fed. (2d) 265; Georgia School-Book Depository, Inc., 1 T.

McClain v. Comm'r

2007 T.C. Summary Opinion 175 · United States Tax Court · Oct 17, 2007

Petitioner claims Stacy Brown as a dependent for 1994 and 1995. Petitioner also claims her to have been a renter who owed him for room and board for those same years. … Board and Room Rental The evidence, including petitioner’s testimony, leads the Court to conclude that petitioner did not conduct his room and board activity primarily with the objective to make a profit.

Huber v. Comm'r

91 T.C.M. 1132 · United States Tax Court · May 9, 2006

V. E&Y Report The value set by E&Y was used to set the board’s compensation and measure the financial performance of Huber. … See, e.g., Kimbell v.

Burwell v. Commissioner

89 T.C. 580 · United States Tax Court · Sep 16, 1987

Hensley testified that he could call a meeting of any congregation in the country “because I am the Chairman of any Board of anywhere in the country.” … See, e.g., United States v. Toy National Bank (N.D. Iowa 1979, 43 AFTR2d 79-954, 79-1 USTC par. 9344 ); Brown v. Commissioner, T.C. Memo. 1980-553 ; Riemers v. Commissioner, T.C. Memo. 1981-456 ; Kellman v.

Knapp Monarch Co. v. Commissioner

1 T.C. 59 · United States Tax Court · Nov 18, 1942

In Commissioner v. … See also Commissioner v. Food Industries, Inc ., 101 Fed. (2d) 748 ; Commissioner v. Schoellkopf , 100 Fed. (2d) 415 ; and Commissioner v.

Jones v. Commissioner

64 T.C. 1066 · United States Tax Court · Sep 23, 1975

Jones and the corporation and were not approved by the board of directors of the corporation in advance, although the board of directors, by general language, subsequently approved and ratified all the acts of the officers … Jones merely relied upon a verbal understanding with his controlled board of directors.

Estate of Jung v. Commissioner

101 T.C. 412 · United States Tax Court · Nov 10, 1993

Cir. 1992); Estate of Kaplin v. Commissioner, 748 F.2d 1109, 1111 (6th Cir. 1984), revg. T.C. Memo. 1982-440 ; Estate of Brown v. Commissioner, 425 F.2d 1406, 1407 (5th Cir. 1970), affg. T.C. Memo. 1969-91 . … Mailman v.

Estate of Miller v. Commissioner

58 T.C. 699 · United States Tax Court · Jul 31, 1972

Petitioners rely on the case of Brown v. … Petitioners’ reliance on Brown v. Routzahn is misplaced.

Litton Business Systems, Inc. v. Commissioner

61 T.C. 367 · United States Tax Court · Dec 26, 1973

The first meeting of the board of directors of New Eureka was held on November 24, 1961. … Lantz Co. v.

Stern v. Commissioner

66 T.C. 91 · United States Tax Court · Apr 13, 1976

During 1968, the principal officers and members of Mutual’s board of directors were as follows: Officers Directors Harold B. Cohen, chairman of the board of directors Albert C. Brody Philip Brody Jerome H. … Watson v. Commissioner, 345 U.S. 544, 551-552 (1953); Williams v. McGowan, 152 F. 2d 570, 572-573 (2d Cir. 1945); Charles W. Miller, 56 T.C. 636, 649, 651 (1971); see C. D.

Industrial Suppliers, Inc. v. Commissioner

50 T.C. 635 · United States Tax Court · Jul 30, 1968

Brown appraised the inventory at $80,000 to $100,000. … Sec. 6214(b); State Farming Co., 40 T.C. 774, 782 (1963); Commissioner v. Disston, 325 U.S. 442, 449 (1945).