Case law

Hauptli v. Commissioner

56 T.C.M. 583 · United States Tax Court · Nov 7, 1988

HAUPTLI, JR., AND BARBARA HAUPTLI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Hauptli v. Commissioner Docket No. 8254-87 United States Tax Court T.C. Memo 1988-518 ; 1988 Tax Ct. … Brown Welding, and presumably Mr.

McNair v. Commissioner

26 T.C. 1221 · United States Tax Court · Sep 28, 1956

In making our decision herein we are not unmindful of Prince v. United States, (Ct. Cl., 1954) 119 F. … The crucial factual distinction is that in Prince the taxpayer, although retired for age and thereafter recalled to active duty in the armed services, did appear before the appropriate retirement board, which board made a

Genesis Oil & Gas, Ltd. v. Commissioner

93 T.C. 562 · United States Tax Court · Nov 6, 1989

Abeles v. Commissioner, 91 T.C. 1019, 1039 (1988); Wisniewski v. Commissioner, T.C. Memo. 1989-60 . … Several of the other cases cited by petitioner involved the statutory phrase “last known address,” e.g., Brown v. Commissioner, 78 T.C. 215 (1982); Shelton v. Commissioner, supra.

Deal v. Commissioner

29 T.C. 730 · United States Tax Court · Jan 29, 1958

Brown, and Margaret D. … United States v. Pelzer , 312 U.S. 399 .

PPG Indus., Inc. v. Commissioner

55 T.C. 928 · United States Tax Court · Dec 31, 1970

See Worcester v. Commissioner, 370 F. 2d 713 (C.A.1, 1966); Equitable Publishing Co. v. Commissioner, 356 F. 2d 514 (C.A.3, 1966); Mahransky v. Commissioner, 321, F. 2d 598 (C.A.3, 1963); Biltmore Homes, Inc. v. … In Pickren v.

Chemplast, Inc. v. Commissioner

60 T.C. 623 · United States Tax Court · Jul 30, 1973

Section 4 of this agreement provided that there would be seven members on Chem-Cell’s board of directors. … The initial board was to be composed of the five members of petitioner’s board of directors plus Richman and one person designated by him.

Heidel v. Commissioner

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

In Van Hook v. … In Bingler v.

Ellery v. Commissioner

4 T.C. 407 · United States Tax Court · Dec 4, 1944

Grossman v. Greenstein, supra. … But in Commissioner v.

Batten, Barton, Durstine & Osborn, Inc. v. Commissioner

9 T.C. 448 · United States Tax Court · Sep 25, 1947

The respondent, in his brief, relies principally upon Helvering v. Edison Bros. Stores, Inc., 133 Fed. (2d) 575; Brown Shoe Co. v. Commissioner, 133 Fed (2d) 582; Commissioner v.

Fed. Home Loan Mortg. Corp. v. Comm'r

125 T.C. 248 · United States Tax Court · Nov 21, 2005

At all relevant times, petitioner was a corporation managed by a board of directors. … Co. v. Brown, 253 U.S. 101, 110 (1920); Halle v. Commissioner, supra at 654; Old Harbor Native Corp. v. Commissioner, 104 T.C. at 201 ; Estate of Franklin v. Commissioner, supra at 762-763; Rev. Rul. 58-234, supra.

Seibold v. Commissioner

31 T.C. 1017 · United States Tax Court · Feb 24, 1959

In 1951 Melba was notified, either by the school board or the State Department of Education, that her temporary certificate would not be renewed again. … Hill v. Commissioner, 181 F. 2d 906 , reversing 13 T. C. 291 was followed in Robert S. Green, 28 T. C. 1154 .

Bank of America Nat'l Trust & Sav. Asso. v. Commissioner

15 T.C. 544 · United States Tax Court · Oct 20, 1950

Co. v. Commissioner, 284 U. S. 552 , and Gulf, Mobile & Northern R. Co. v. … Higgins v. Smith, supra; Sidney M. Shoenberg, supra; Thal v. Commissioner, 142 Fed. (2d) 874; cf. Corliss v. Bowers, 281 U. S. 376 .

Roehl Constr. Co. v. Commissioner

17 T.C. 1037 · United States Tax Court · Dec 26, 1951

Roehl Construction Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Roehl Constr. Co. v. Commissioner Docket Nos. 17404, 22979 United States Tax Court 17 T.C. 1037 ; 1951 U.S. Tax Ct. … At the same meeting of the board of directors Dorothy Roehl Berry was elected president of petitioner and Otto T.

T. J. Moss Tie Co. v. Commissioner

18 T.C. 188 · United States Tax Court · May 7, 1952

A. 689 ; Mutual Aid & Benefit Ass'n v. Commissioner , 42 F. 2d 619 ; and Gimbel v. … Eagan v. Commissioner , 43 F. 2d 881 .

W. E. Gabriel Fabrication Co. v. Commissioner

42 T.C. 545 · United States Tax Court · Jun 16, 1964

Gregory v. Helvering, 293 U.S. 465 (1935). See also 3 Mertens, Law of Federal Income Taxation, sec. 20.103. … Appleby, 35 T.C. 755 (1961), aff'd. 296 P. 2d 925 (C.A. 3, 1962), certiorari denied 370 U.S. 910 (1962); Bonsall v. Commissioner, 317 P. 2d 61 (C.A. 2, 1963), affirming a Memorandum Opinion of this Court; and Curtis v.

Wall Prods. v. Comm'r

11 T.C. 51 · United States Tax Court · Jul 20, 1948

Wall Products, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Wall Prods. v. Comm'r Docket No. 10277 United States Tax Court 11 T.C. 51 ; 1948 U.S. Tax Ct. LEXIS 124 ; 78 U.S.P.Q. … Petitioner's board of directors was composed of the same three persons.

Gajewski v. Commissioner

84 T.C. 980 · United States Tax Court · May 23, 1985

Prior to 1934, when there was no specific provision governing the deductibility of gambling losses, the Board of Tax Appeals adopted a "netting” approach. Thus, in McKenna v. … The Board extended this netting approach to the casual gambler’s gross income calculation in Frey v.

Estate of Spear v. Commissioner

65 T.C.M. 2668 · United States Tax Court · May 18, 1993

Gilbert Brown in Spear v. Brown Petitioners offered into evidence Brown's deposition from Leon Spear's malpractice suit against Brown. Respondent objected on hearsay grounds. … Consequently, we hold that Leon Spear's deposition in Spear v. Brown was properly excluded as inadmissible hearsay in *285 this case. c. Testimony of Robert Wilson in United States v.

Epstein v. Commissioner

70 T.C. 439 · United States Tax Court · Jun 13, 1978

The corporation’s board of directors was empowered to terminate the plan. … In Greenwald v.

Gordon v. Commissioner

73 T.C. 736 · United States Tax Court · Jan 30, 1980

See Gilday v. Commissioner, 62 T.C. 260, 262 (1974); Morris v. Commissioner, 30 T.C. 928, 929 (1958); Black v. Commissioner, 19 T.C. 474 (1952). … However, the Board refused to include the fraud addition to tax in its order of dismissal.