Case law

Brown v. Commissioner

52 T.C. 50 · United States Tax Court · Apr 8, 1969

BROWN and BILLY N. BROWN all of [my] property of every kind and character and wherever located, whether in the State of Texas or any other state, in full fee simple, share and share alike. … It should be noted that the Board relied extensively on Rossetti v. Benavides, 195 S.W. 208 (Tex.Civ.App. 1917). One writer in discussing Rossetti v.

Brown v. Commissioner

22 T.C. 58 · United States Tax Court · Apr 13, 1954

Brown v. Commissioner

24 T.C. 256 · United States Tax Court · May 24, 1955

Brown and Elmer L. … Cannon v. Nicholas, (C. A. 10) 80 F. 2d 934 ; Flack’s Annotated Code of Maryland, art. 83, secs. 1, 12; Fladung v. Rose, 58 Md. 13 ; Eder v.

Brown v. Commissioner

11 T.C. 744 · United States Tax Court · Nov 1, 1948

Brown, Jr., H. L. Brown and Mrs. … Brown, Jr., H. L. Brown and Mrs.

Brown v. Commissioner

25 T.C. 920 · United States Tax Court · Jan 31, 1956

Brown to his two children on September 8,1947; that such cash was used to redeem the 74 notes which the 1937 deed of trust secured; and that the subsequent exchange of such notes for petitioner’s personal notes in 1949 resulted … Brown as the donor of alleged gifts to his children on the one hand, and himself as their guardian and custodian of the gifts, on the other. Commissioner v. Culbertson, 337 U.

Brown v. Commissioner

20 T.C. 73 · United States Tax Court · Apr 14, 1953

The following quotation from Yerkes v. Yerkes, 200 Pa. 419, 423 , 50 Atl. 186 , approved by the Supreme Court in Shaffer v. … Scott's Estate, supra; Greenough v. Small, supra.

Brown v. Commissioner

1 T.C. 760 · United States Tax Court · Mar 16, 1943

Respondent contends that under North American Oil Consolidated v. Burnet, 286 U. … Burnet v. Sanford & Brooks Co., 282 U. S. 859 ; Penn v. Robertson, 115 Fed. (2d) 167. But there are exceptions. Cf. E. B. Elliott Co., 45 B. T. A. 82.

Brown v. Commissioner

16 T.C. 623 · United States Tax Court · Mar 26, 1951

Brown. … Brown under the agreement.

Brown v. Commissioner

93 T.C. 736 · United States Tax Court · Dec 19, 1989

In November 1983, at age 62, petitioner retired from Brown & Root, Inc. On January 19, 1984, he received a $344,505.97 lump-sum distribution from the Brown & Root, Inc. … Substantially the same argument made by petitioners was made and rejected in Sullivan v. Commissioner, 76 T.C. 1156 (1981), affd. by unpublished order (10th Cir. 1983). Cf. Warfield v. Commissioner, 84 T.C. 179 (1985).

Brown v. Commissioner

19 T.C. 87 · United States Tax Court · Oct 28, 1952

Brown was terminated in 1945 or 1946, causing income and gains of those years to be taxable to petitioner and his wife rather than the estate. 2 Carrie L. … Brown consisted of large interests in real property, corporate securities, capital, mineral rights and royalties. She died in October 1941. Her will was probated soon thereafter.

Brown v. Commissioner

54 T.C. 1475 · United States Tax Court · Jul 14, 1970

See Boeing v. United States, supra, 168 F. Supp. at 767-769, 144 Ct. Cl. at 84-87; Browne v. United States, supra; Burgher v. Campbell, supra, 244 F. 2d at 864-865 ; Lakin v. … Cordy v. Commissioner, 36 T.C. 865 (1961), on which plaintiff leans heavily, is distinguished in Browne v. United States, supra.

Brown v. Commissioner

41 T.C. 854 · United States Tax Court · Mar 19, 1964

The board of directors of West Coast voted to dissolve the corporation on April 28, 1953. … Brown President” relative to elections under section 4 (a) and (b) of the act.

Brown v. Commissioner

75 T.C. 172 · United States Tax Court · Oct 28, 1980

Brown $3,666.56 6/15/73 $916.64 Jeffrey N. Brown 2,749.94 6/27/73 687.49 Rbbert N. Brown Susan A. Brown 2,749.94 6/11/73 687.49 Rebecca E. Brown 2,749.94 Peggy A. … Hancock v. Maynard, supra.

Brown Deer v. Commissioner

86 T.C. 975 · United States Tax Court · May 19, 1986

. • On April 1, 1979, Village of Brown Deer (petitioner), a municipal corporation of Wisconsin, issued $4,500,000 of General Obligation Storm Sewer Bonds (bonds) to finance the construction of proposed storm sewers and related

Brown Group v. Commissioner

104 T.C. 105 · United States Tax Court · Jan 25, 1995

For instance, in Goodwin v. … But cf. our decision in Huntsman v.

Brown Shoe Co. v. Commissioner

10 T.C. 291 · United States Tax Court · Feb 13, 1948

Brown Group v. Commissioner

102 T.C. 616 · United States Tax Court · Apr 12, 1994

BROWN GROUP, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Brown Group v. Commissioner Docket No. 104-92 United States Tax Court 102 T.C. 616 ; 1994 U.S. Tax Ct. LEXIS 26 ; 102 T.C. … In Davis v.

Board v. Commissioner

14 T.C. 322 · United States Tax Court · Mar 1, 1950

See Central National Bank of Cleveland v. United States (Ct. Cls.), 41 Fed. Supp. 239, 247; Commissioner v. Nathan’s Estate (C. C. A., 7th Cir.), 159 Fed. (2d) 546. … Stone v. Stone, 319 Mich. 194 ; 29 N. W. (2d) 271 , with Lowry v. Kavanagh, 322 Mich. 532 ; 34 N. W. (2d) 60 .

Brown-Forman Corp. v. Commissioner

94 T.C. 919 · United States Tax Court · Jun 25, 1990

In Commissioner v. … Turtle Wax, Inc. v.

Alex Brown, Inc. v. Commissioner

60 T.C. 364 · United States Tax Court · Jun 11, 1973

Dixie, Inc. v. Commissioner, 277 F. 2d 526 (C.A. 2, 1960), affirming 31 T.C. 415 (1958); Egan, Inc., v. Commissioner, 236 F. 2d 343 (C.A. 8, 1956), affirming a Memorandum Opinion of this Court; J. … United States v. Donruss Co., supra.