Case law

Zoltan v. Commissioner

79 T.C. 490 · United States Tax Court · Sep 20, 1982

In Brown v. Commissioner, 73 T.C. 156 (1979), this Court found that the taxpayer enrolled her son in boarding school to enable her to seek and hold gainful employment. … In defining "child care” we said, "incidentals that go with providing well-being and protection, such as room, board, and supervision before and after the normal school day, should be deductible.” Brown v.

Beeley v. War Contracts Price Adjustment Board

12 T.C. 61 · United States Tax Court · Jan 27, 1949

This proceeding was heard and petitioners’ brief was filed prior to the Supreme Court’s decision in Lichter v. United States, 334 U. S. 742 . … It was not involved under the facts in the three cases which were before the Supreme Court in Lichter v. United States, supra.

Fine v. War Contracts Price Adjustment Board

9 T.C. 600 · United States Tax Court · Oct 7, 1947

That construction of the pertinent part of section 403 (a) (5) (B) was made first in Wolff v. Macauley, 8 T. C. 146 , which was not reviewed by the Court.

Dunkin v. Comm'r

124 T.C. 180 · United States Tax Court · Mar 31, 2005

Petitioner participated in a defined benefit pension plan (the pension plan) administered by the Board of Pension Commissioners (the pension board). … In re Marriage of Brown, 544 P.2d 561, 565 (Cal. 1976).

O'Donnabhain v. Commissioner

134 T.C. 34 · United States Tax Court · Feb 2, 2010

Brown Petitioner’s expert, Dr. George R. Brown (Dr. Brown), is a licensed physician, board certified in adult psychiatry by the American Board of Psychiatry and Neurology. Dr. … Dietz), is a licensed physician and board certified in psychiatry by the American Board of Psychiatry and Neurology. Like Dr. Brown, he is a Distinguished Fellow of the American Psychiatric Association.

Irvin's Trust v. Commissioner

29 T.C. 846 · United States Tax Court · Feb 14, 1958

Brown, Vernon K. Irvin, and Kobert L. Irvin, acceptors in joint tenancy and children of Elmer Irvin, should compose the board of trustees and executive officers for conducting the business of the trust. … Swanson v. Commissioner, 296 U. S. 362 ; Helvering v. Combs, 296 U. S. 365 ; and Helvering v. Coleman-Gilbert Associates, 296 U. S. 369 .

Hemmings v. Commissioner

104 T.C. 221 · United States Tax Court · Feb 6, 1995

the Board) within 60 days. … Brown v. United States, 976 F.2d 1104 (7th Cir. 1992). Although respondent, in her objection to petitioners’ motion, indicates that a material fact is at issue, she does not specify what is in dispute. The U.S.

Estate of Semone Grossman, Richard M. Frome, Preliminary

United States Tax Court · May 27, 2021

Windows On World, 23 A.D.3d 967, 969-970 (3d Dep’t 2005) (comparing Matter of Seidel, 132 A.D.2d at 730, and Matter of Esmond, 26 A.D.2d at 884-885, with Matter of Brown, 40 N.Y.2d 938, 939 (1976), and Steele v. … The New York Appellate Division upheld the board’s decision: “There is an extremely 27 Indeed, the divorce at issue in Matter of Meltzer v.

Chisholm v. Commissioner

26 T.C. 253 · United States Tax Court · May 11, 1956

Brown. … Sec. 811 (f); see Morgan v. Commissioner, 309 U. S. 78 . Thus, if the first paragraph stood alone, this first issue would have to be decided for the petitioners.

Texas Trade School v. Commissioner

30 T.C. 642 · United States Tax Court · Jun 18, 1958

Brown: President Ross A. Peterson: Vice president and director of training Allen Melton: Vice president and counsel O. J. … Brown, Walter K.

Estate of Brown v. Commissioner

55 T.C.M. 1249 · United States Tax Court · Jul 12, 1988

BROWN, Deceased, KEITH WAYNE BROWN and KENNITH RAY BROWN, Administrators, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Estate of Brown v. … Brown ( Ballard v. Commissioner, 740 F.2d 659 , 662-663 (8th Cir. 1984) , affg. on this issue a Memorandum Opinion of this Court; Vannaman v.

Robinson v. Commissioner

78 T.C. 550 · United States Tax Court · Apr 7, 1982

Browne v. Commissioner, 73 T.C. 723, 726 (1980); Diaz v. Commissioner, 70 T.C. 1067, 1074 (1978); Glenn v. Commissioner, 62 T.C. 270, 275 (1974); Weiszmann v. … Sec. 1.162-5(b)(1), Income Tax Regs.; Browne v. Commissioner, supra; Bodley v. Commissioner, 56 T.C. 1357, 1361 (1971).

Estate of Gillespie v. Commissioner

103 T.C. 395 · United States Tax Court · Aug 25, 1994

Background On March 18, 1991, respondent mailed a 30-day letter proposing to increase by $9,064,361 the estate tax of the Estate of Pauline Brown Gillespie (decedent). … See Commissioner v. Brown, 380 U.S. 563, 570-571 (1965); Union Pacific Corp. v. Commissioner, 91 T.C. 32, 38-40 (1988).

Brown v. Comm'r

2014 U.S. Tax Ct. LEXIS 52 · United States Tax Court · Apr 17, 2014

JEROME JULIUS BROWN, SR., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Brown v. Comm'r Docket No. 28061-13. United States Tax Court 2014 U.S. Tax Ct. … Naftel v. Commissioner , 85 T.C. 527 , 529 (1985) ; Breman v. Commissioner , 66 T.C. 61 , 66 (1976) .

Michigan Chemical Corp. v. Renegotiation Bd.

49 T.C. 488 · United States Tax Court · Feb 19, 1968

Respondent relies, in part, on Morgan Construction Co. v. Secretary of War, 11 T.C. 764 (1948). … Renegotiation Board Regs. sec. 1453.2(b) (3).

Maurine DeWolfe Brown v. Commissioner

12 T.C.M. 948 · United States Tax Court · Aug 20, 1953

Maurine DeWolfe Brown v. Commissioner. Maurine DeWolfe Brown v. Commissioner Docket No. 35476. United States Tax Court 1953 Tax Ct. Memo LEXIS 143 ; 12 T.C.M. (CCH) 948 ; T.C.M. (RIA) 53281 ; August 20, 1953 *143 1. … Brown. On December 31, 1942, the petitioner and Clarence R. Brown executed a document entitled "Property Settlement Agreement" (hereinafter referred to as the "1942 agreement").

Estate of Owen v. Commissioner

104 T.C. 498 · United States Tax Court · Apr 20, 1995

United States v. American Trucking Associations, 310 U.S. 534, 543-544 (1940); U.S. Padding Corp. v. Commissioner, 88 T.C. 177, 184 (1987), affd. 865 F.2d 750 (6th Cir. 1989); Huntsberry v. … Huntsberry v. Commissioner, 83 T.C. at 747-748 ; see Pallottini v. Commissioner, 90 T.C. 498, 503 (1988), and cases there cited.

Marshall v. Commissioner

1 T.C. 442 · United States Tax Court · Jan 12, 1943

Compare, however, Commissioner v. Buck, 120 Fed. (2d) 775; Helvering v. Bok, 132 Fed. (2d) 365, affirming Mary Louise Bok, 46 B. T. A. 678; and Brown v. Commissioner, 131 Fed. (2d) 640, affirming Antoinette K. … Brown, 46 B. T. A. 782.

Brandon Brown & Christi Cloaninger Brown v. Commissioner

2018 T.C. Summary Opinion 6 · United States Tax Court · Feb 5, 2018

Summary Opinion 2018-6 UNITED STATES TAX COURT BRANDON BROWN AND CHRISTI CLOANINGER BROWN, Petitioners v. … Co. v. Commissioner, 4 B.T.A. at 106; see also Gibson & Assocs., Inc. v. Commissioner, 136 T.C. at 233.

Estate of Maresi v. Commissioner

6 T.C. 582 · United States Tax Court · Mar 26, 1946

A., 1st Cir.), 128 Fed. (2d) 618, decided long after the Humes case, a determination of the Board of Tax Appeals (Estate of Francis Browne Grinnell, 44 B. T. … Humes v. United States, supra.