Case law

Estate of Heck v. Comm'r

83 T.C.M. 1181 · United States Tax Court · Feb 5, 2002

See Furman v. Commissioner, T.C. Memo. 1998-157. See also Estate of Maggos v. Commissioner, T.C. Memo. 2000-129 and Estate of Hendrickson v. Commissioner, T.C. … As we stated in Estate of Andrews v.

Carson v. Commissioner

71 T.C. 252 · United States Tax Court · Nov 22, 1978

Thatcher Estate Co. v. Commissioner, 38 B.T.A. 336 (1938), the Board redetermined a deficiency in gift tax under the Revenue Act of 1924. … The Board thought it helpful, in arriving at its conclusion, to note ( 38 B.T.A. at 343 ) that— In Ould v.

Norbury Sanatorium Co. v. Commissioner

9 T.C. 586 · United States Tax Court · Oct 6, 1947

The Norbury Sanatorium Co., Petitioner, v. Commissioner of Internal Revenue, Respondent Norbury Sanatorium Co. v. Commissioner Docket No. 12957 United States Tax Court 9 T.C. 586 ; 1947 U.S. Tax Ct. … Said Board shall have the right to meet and hear such evidence as they may consider proper and appropriate and make any other investigation as they see fit, and the written award or determination of such Board of arbitration

Kamis Engineering Co. v. Commissioner

60 T.C. 763 · United States Tax Court · Aug 27, 1973

Manilow v. United States, 315 F. Supp. 28 (N.D. Ill. 1970). … Commissioner v.

Stewart v. Commissioner

53 T.C. 344 · United States Tax Court · Nov 26, 1969

Despite the efforts of the board of directors and corporate officers of AIC Corp. to persuade the union not to withdraw the profit-sharing accounts, the union ultimately prevailed, and the Ed Friedrich Division agreed to … United States v. Martin, 337 F. 2d 171 (C.A. 8, 1964); United States v. Peebles, 331 F. 2d 955 (C.A. 5, 1964); United States v. Johnson, 331 F. 2d 943 (C.A. 5, 1964) ; Jack E.

Sibole v. Commissioner

28 T.C. 40 · United States Tax Court · Apr 16, 1957

The Supreme Court of the United States, in Haynes v. United States, 353 U. … The petitioners must prevail on the authority of Haynes v. United States, supra. Decision will be entered for the fetitioners.

Heidel v. Commissioner

56 T.C. 95 · United States Tax Court · Apr 20, 1971

In Van Hook v. … In Bingler v.

Prokop v. Commissioner

16 T.C.M. 313 · United States Tax Court · May 13, 1957

Alice V. Prokop v. Commissioner. Harry W. Prokop and Alice V. Prokop, his wife, v. Commissioner. Prokop v. Commissioner Docket Nos. 49495, 49496. United States Tax Court T.C. Memo 1957-75 ; 1957 Tax Ct. … It was the function of the executive board of the Union on the recommendation of Brown to *187 set the policy on the collection of said permit fees.

Estate of Woodard v. Commissioner

64 T.C. 999 · United States Tax Court · Aug 28, 1975

At this point we feel not unlike Judge Hutcheson must have felt as he began his opinion in Dolores Crabb v. … United States v. Estate of Grace, 395 U.S. 316 (1969), involved “crossed income” interest, not “crossed powers.”

Mahoney Motor Co. v. Commissioner

15 T.C. 118 · United States Tax Court · Aug 11, 1950

Mahoney Motor Co., Petitioner, v. Commissioner of Internal Revenue, Respondent Mahoney Motor Co. v. Commissioner Docket No. 22051 United States Tax Court 15 T.C. 118 ; 1950 U.S. Tax Ct. … Brown, Esq ., and Wilbur R. Irwin, C. P. A ., for the petitioner. George E. Gibson, Esq ., for the respondent. Johnson, Judge .

Fry v. Commissioner

5 T.C. 1058 · United States Tax Court · Nov 14, 1945

Fry, Petitioner, v. Commissioner of Internal Revenue, Respondent Fry v. Commissioner Docket No. 758 United States Tax Court 5 T.C. 1058 ; 1945 U.S. Tax Ct. … Fisher v. Commissioner , 108 Fed. (2d) 707 ; Peck & Peck , 42 B. T. A. 651 ; Anna V. Gilmore , 44 B. T. A. 881 ; affd., 130 Fed. (2d) 791 ; Hortense A. Menefee , 46 B. T.

G C Services Corp. v. Commissioner

73 T.C. 406 · United States Tax Court · Dec 3, 1979

Balthrope v. Commissioner, 356 F.2d 28 (5th Cir. 1966), affg. a Memorandum Opinion of this Court; Lucas v. Commissioner, 58 T.C. 1022 (1972). … See Annabelle Candy Co. v. Commissioner, supra at 7.

Munter v. Commissioner

5 T.C. 39 · United States Tax Court · May 16, 1945

The majority opinion relies upon three cases for support: Edson v. Lucas, 40 Fed. (2d) 398; Johnson v. Commissioner, 86 Fed. (2d) 710; and Tyson v. Commissioner, 146 Fed. (2d) 50. … That case is Edson v. Lucas. In that case the court reversed a decision of the Board of Tax Appeals which had held incomplete a gift of shares of stock in the Texas Oil Co. which Mrs. J. A.

Johnston v. Commissioner

52 T.C. 792 · United States Tax Court · Aug 11, 1969

To the contrary, see Phillips v. Commissioner, 283 U.S. 589 . … Sec. 6213(a), I.R.C. 1954; Commissioner v. Gooch Co., 320 U.S. 418 ; Page v. Commissioner, 297 F. 2d 733 ; Franklin H. Moyer, 1 B.T.A. 75 ; Estate of Charles Schmalstig, 43 B.T.A. 433 .

Modern Home Life Ins. Co. v. Commissioner

54 T.C. 935 · United States Tax Court · May 7, 1970

In support of his position, respondent relies on the principles of Brown v. … Corp. v. Commissioner, 47 F. 2d 582 (C.A. 2, 1931).

Chapman v. Commissioner

9 T.C. 619 · United States Tax Court · Oct 9, 1947

Irwin v. Gavit, 268 U. S. 161 ; Bland v. Commissioner, 102 Fed. (2d) 157; certiorari denied, 308 U. S. 563 . … Barnhill v. Commissioner, 148 Fed. (2d) 913; Commissioner v. Flowers., 326 U. S. 465 ; George F. Thompson, 6 T. C. 285 ; affd., 161 Fed. (2d) 185. Reviewed by the Court. Decision will he entered, for the respondent.

Pacific Coast Music Jobbers, Inc. v. Commissioner

55 T.C. 866 · United States Tax Court · Feb 25, 1971

They did, however, sign, as directors, minutes for a meeting of the board of directors of Pacific on August 31,1963. … See Commissioner v. Brown, 380 U.S. 563, 571 (1965). While the stock was in escrow, the dividends paid by Pacific were being used to amortize Hansen’s obligation to the sellers.

Golden Rule Church Ass'n v. Commissioner

41 T.C. 719 · United States Tax Court · Feb 28, 1964

Speiser v. Randall , 357 U.S. 513 , 518 (1958) ; United States v. Seeger , 326 F. 2d 846 (C.A. 2, 1964). See Sherbert v. Verner , 374 U.S. 398 , 404-406 (1963) . … Compare Justice Reed's dissent in McCollum v. Board of Education , 333 U.S. 203 , 249 (1948) , and Justice Douglas' concurring opinion in First Unit. Church v.

Professional Ins. Agents v. Commissioner

78 T.C. 246 · United States Tax Court · Feb 17, 1982

It is an organization of the same general class as a chamber of commerce or board of trade. … In support of its argument, petitioner relies on our opinion in New York State Assn. of Real Estate Boards Group Insurance Fund v.

Estate of McWhorter v. Commissioner

69 T.C. 650 · United States Tax Court · Feb 2, 1978

In Roe, Cummer Lime’s board of directors declared a dividend of $1,800,000 on February 9, 1926. … See Attebury v. United States, supra at 1170-1171; and McKelvy v. United States, supra at 1227.