Case law

Greenspun v. Commissioner

72 T.C. 931 · United States Tax Court · Aug 28, 1979

In 1968, he voluntarily appeared before the Nevada Gaming Policy Board to voice his support of Hughes’ acquisition of two casinos. … In Commissioner v.

Estate of Briden v. Commissioner

11 T.C. 1095 · United States Tax Court · Dec 31, 1948

Hensaw v. Miller, 17 How. 212, 219, 222 . … Mitchell v. Commissioner, 89 Fed. (2d) 873.

Kellogg v. Commissioner

2 T.C. 1126 · United States Tax Court · Dec 15, 1943

The petitioner was an officer and a member of the board of trustees of The Miami-Battle Creek, a Florida charitable corporation without shares. … The Commissioner defends the determination that the relinquishment of the credits is the realization of income by a logical argument built upon Helvering v. American Dental Co., 318 U. S. 322 , and Helvering v.

Cal-Maine Foods, Inc. v. Commissioner

93 T.C. 181 · United States Tax Court · Aug 8, 1989

See Penrod v. … United States v. James, 478 U.S. 597, 606 (1986); Hernandez-Colon v. Secretary of Labor, 835 F.2d 958 (1st Cir. 1988); Elliston v.

United Artists Theatre Circuit, Inc. v. Commissioner

1 T.C. 424 · United States Tax Court · Jan 5, 1943

On January 7, 1937, petitioner's board of directors unanimously promulgated a plan of recapitalization. … E. (2d) 618 ; Wiedersum v. Atlantic Cement Products , 261 App. Div. 305 ; 25 N. Y. S. (2d) 496, 501 ; Breslav v. New York & Queens Elec. L. & P. Co ., 249 App. Div. 181 ; 291 N. Y. S. 932 ; Patterson v.

Standard Coal, Inc. v. Commissioner

20 T.C. 208 · United States Tax Court · Apr 29, 1953

Investment Co. v. Commissioner, (C. A. 8) 88 F. 2d 582 ; Jesse Lee Brown v. Heiner, (D. C. W. D. Penn.) 15 A. F. T. R. 899. … This was not a situation like Mascot Stove Co. v. Commissioner, (C. A. 6) 120 F. 2d 153 , Templeton’s Jewelers, Inc. v United States, (C. A. 6) 126 F. 2d 251 , nor Chicago Stadium Corporation, 13 T.

Rogers v. Commissioner

11 T.C. 435 · United States Tax Court · Sep 28, 1948

(b) Three members of the Board of Directors shall be persons nominated by the American Liberty Steamship Corporation, hereinafter designated *76 as "Liberty Group", and an equal number of the Board of Directors shall be persons … Rogers shall have at all times equal representation upon the Board of Directors.

American Bemberg Corp. v. Commissioner

10 T.C. 361 · United States Tax Court · Feb 25, 1948

A. 1002; Zimmern v. Commissioner, 28 Fed. (2d) 769, reversing 9 B. T. A. 1382; and Buckland v. United States, 66 Fed. Supp. 681. … V. Burnell, vice president of Stone & Webster, on or about April 15, 1944, and Burnell’s testimony at the hearing.

Victory Glass, Inc. v. Commissioner

11 T.C. 656 · United States Tax Court · Oct 21, 1948

C. 1082 ; Brown Shoe Co., 10 T. C. 291 . … La Belle Iron Works v. United States, 256 U. S. 377 . In Dill & Collins Co., 18 B. T.

Aprill v. Commissioner

13 T.C. 707 · United States Tax Court · Nov 8, 1949

Aprill, Petitioner, v. Commissioner of Internal Revenue, Respondent Aprill v. Commissioner Docket No. 20091 United States Tax Court 13 T.C. 707 ; 1949 U.S. Tax Ct. … A., 5th Cir.), 135 Fed. (2d) 378 , with Blair v. Rosseter (C. C.

Blyth v. Commissioner

21 T.C. 275 · United States Tax Court · Nov 23, 1953

Blyth, Petitioner, v. Commissioner of Internal Revenue, Respondent Blyth v. Commissioner Docket No. 40636 United States Tax Court 21 T.C. 275 ; 1953 U.S. Tax Ct. … This school was a boarding school and petitioner paid none of the costs of her son's attendance therein.

Gino v. Commissioner

60 T.C. 304 · United States Tax Court · May 31, 1973

Cohan v. Commissioner, 39 F. 2d 540 (C.A. 2, 1930). … Cohan v. Commissioner, supra. 3.

Audenried v. Commissioner

26 T.C. 120 · United States Tax Court · Apr 20, 1956

Commissioner v. Cardeza's Estate, 173 F. 2d 19 . In Fidelity-Philadelphia Trust Co. v. … Gund’s Estate v. Commissioner, 113 F. 2d 61 , certiorari denied 311 U. S. 696 .

West Side Tennis Club v. Commissioner

1 T.C. 302 · United States Tax Court · Dec 18, 1942

Petitioner cites Stevens v. Nave-McCord Mercantile Co., 150 Fed. 71 ; Darby-Lynde Co. v. Alexander, 51 Fed. (2d) 56; Haggar Co. v. Helvering, 308 U. S. 389 ; United States v. Kirby, 74 U. S. 482 ; Heyenfeldt v. … Both the Board and the Second Circuit rejected these contentions. West Side Tennis Club, supra.

Kurtzon v. Commissioner

17 T.C. 1542 · United States Tax Court · Mar 21, 1952

In support of his contention, petitioner in substance says: The renegotiation claim which the War Contracts Price Adjustment Board had was one against Garcy Lighting Company, a partnership, and it was not against petitioner … United States v. Sankozy, 99 F. Supp. 736, 742 . We think petitioner’s Ground 2 cannot be sustained. The first paragraph of the stipulation of facts reads: 1.

Forest Press, Inc. v. Commissioner

22 T.C. 265 · United States Tax Court · May 7, 1954

Forest Press, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Forest Press, Inc. v. Commissioner Docket No. 41590 United States Tax Court 22 T.C. 265 ; 1954 U.S. Tax Ct. … In Roche's Beach, Inc. v. Commissioner , and C. F. Mueller Co. v.

Potter v. Comm'r

27 T.C. 200 · United States Tax Court · Oct 31, 1956

Skemp v. Commissioner, (C. A. 7, 1948) 168 F. 2d 598 , reversing 8 T. C. 415 ; Brown v. Commissioner, (C. A. 3, 1950) 180 F. 2d 926 , reversing 12 T. C. 1095 , certiorari denied 340 U. S. 814 ; and Albert T. … C. 794 , where this Court decided to follow the Skemp and Brown decisions.

Lewis v. Commissioner

49 T.C. 684 · United States Tax Court · Mar 27, 1968

Wolf, 29 T.C. 441 , 449-450 (1957), affirmed in part and reversed in part 264 F. 2d 82 (C.A. 3, 1959); Wolfsen v. Smyth, 223 F. 2d 111 (C.A. 9, 1955); Brown v. United States, 37 F. Supp. 444 (Ct. … Burg, 283 Mich. 73, 83 , 276 N.W. 904, 907 (1937); Hollister v. Kinyon's Estate, 195 Mich. 261, 268 , 161 N.W. 962, 965 (1917). 5 Barbier v. Young, 115 Mich. 100, 101 , 72 N.W. 1096 (1897), interpreted McHugh v.

Dean v. Commissioner

10 T.C. 672 · United States Tax Court · Apr 21, 1948

James Newton Dean, Petitioner, v. Commissioner of Internal Revenue, Respondent Dean v. Commissioner Docket No. 13301 United States Tax Court 10 T.C. 672 ; 1948 U.S. Tax Ct. … The general counsel of ERCO reported to its board of directors, at their meeting on June 9, 1944, that the Salary Stabilization Unit had approved the company's contracts with its employees, and the board was also advised

Lewis v. Commissioner

23 T.C. 538 · United States Tax Court · Dec 28, 1954

This intent test was stated in Commissioner v. Culbertson, 337 U. … the deficiency, * • * the Board shall have iurisdietion to determine the amount of such overpayment, and such amount shall, when the decision of the Board has become final, be credited or refunded to the taxpayer.