Case law

M. W. Zack Metal Co. v. Commissioner

22 T.C. 349 · United States Tax Court · May 19, 1954

Zack Metal Company, Petitioner, v. Commissioner of Internal Revenue, Respondent M. W. Zack Metal Co. v. Commissioner Docket No. 32829 United States Tax Court 22 T.C. 349 ; 1954 U.S. Tax Ct. … Petitioner's board of directors established policies regarding these *212 matters.

Ohio Teamsters Educational & Safety Training Trust Fund v. Commissioner

77 T.C. 189 · United States Tax Court · Aug 4, 1981

See Federation Pharmacy Services v. Commissioner, 72 T.C. 687, 691 (1979), affd. 625 F.2d 804 (8th Cir. 1980); B.S.W. Group, Inc. v. Commissioner, 70 T.C. 352, 356-357 (1978); Golden Rule Church Association v. … Grant-Jacoby, Inc. v. Commissioner, 73 T.C. 700, 708 (1980); Armantrout v. Commissioner, 570 F.2d 210, 212-213 (7th Cir. 1978).

Merkel v. Commissioner

109 T.C. 463 · United States Tax Court · Dec 30, 1997

The Board of Tax Appeals (the Board) agreed with the Commissioner that the rationale of United States v. … Origin of the Net Assets Test The Board’s approach to a taxpayer in financial distress being discharged of an indebtedness, which approach was crystallized in Lakeland Grocery Co. v.

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

Estate of Wallace v. Commissioner

95 T.C. 525 · United States Tax Court · Nov 14, 1990

Wallace was founder, controlling shareholder, president, and chairman of the board of directors of Springhill Medical, Inc.; president, controlling shareholder, and chairman of the board of directors of H&W Pipeline Corp. … Tulia Feedlot, Inc. v. United States, 513 F.2d 800, 805 (5th Cir. 1975); Charles Schneider & Co. 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.

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.

American Pipe & Steel Corp. v. Commissioner

25 T.C. 351 · United States Tax Court · Nov 30, 1955

American Pipe & Steel Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent. W. G. Krieger Co. (Formerly Palos Verdes Estates, Inc.), Petitioner, v. … Commissioner of Internal Revenue, Respondent American Pipe & Steel Corp. v. Commissioner Docket Nos. 28539, 28565 United States Tax Court 25 T.C. 351 ; 1955 U.S. Tax Ct.

Manton v. Commissioner

11 T.C. 831 · United States Tax Court · Nov 22, 1948

A. 812; Cole v. Commissioner (C. C. A., 9th Cir.), 81 Fed. (2d) 485, reversing 29 B. T. A. 602. … “The Bureau’s interpretation has been sustained by the Board of Tax Appeals in various cases but was rejected by a divided court in Cole v. Commissioner (81 F. (2d) 485).

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.

Robertson v. Commissioner

37 T.C. 1153 · United States Tax Court · Mar 28, 1962

Schmidt, as chairman of the department of economics, advised the petitioner that, in accordance with the rules of the board of regents, he would not be recommended for reappointment for the next academic year. … Welch v. Helvering, 290 U.S. 111 . However, as we stated in Robert S. Green, 28 T.C. 1154 : The law, concerning the deductibility of such expenses, has been fairly well established since Hill v.

Wilkins Pontiac v. Commissioner

34 T.C. 1065 · United States Tax Court · Sep 21, 1960

In Putnam v. … Without passing on the question whether such a contingent liability would be accruable in 1955 (but see Brown v.

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.

Coshocton Sec. Co. v. Commissioner

26 T.C. 935 · United States Tax Court · Aug 14, 1956

See O'Sullivan Rubber Co. v. Commissioner, 120 F. 2d 845 (C. A. 2, 1941); American Package Corp. v. Commissioner, 125 F. 2d 413 (C. A. 4, 1942). … Pomerene, one of petitioner’s directors during 1940 and several years thereafter, was asked when the first time was that he as a member of the board of directors discussed the question of whether or not petitioner could have

Fairfax Auto Parts, Inc. v. Commissioner

65 T.C. 798 · United States Tax Court · Jan 26, 1976

The board of directors of NOVA comprised these four persons during these years. On December 31, 1971, and December 31, 1972, William P. … United States v. Cartwright, 411 U.S. 546 (1973). Our holding today is in accord with the legislative history and basic purpose of sections 1561 and 1563.

Ellis v. Commissioner

26 T.C. 694 · United States Tax Court · Jun 26, 1956

C. 99 , but also inconsistent with Matteson v. United States, (N. D., N. Y.) 147 F. Supp. 535 , and Estate of Theodore Geddings Tarver, 26 T. C. 490 . … Estate of Lama Brown Chisholm, 26 T. C. 253 .

Crescent Mfg. Co. v. Commissioner

7 T.C.M. 630 · United States Tax Court · Aug 31, 1948

Brown, deceased, and a distributee of the assets of The Crescent Manufacturing Company et al. 1 v. Commissioner. Crescent Mfg. Co. v. Commissioner Docket Nos. 12200, 13653, 13654, 13655, 13656, 13657, 13658. … New York Central & Hudson River Railroad v. United States, 212 U.S. 481 , 492-495 ; Philadelphia, Wilmington & Baltimore Railroad Co. v. Quigley, 62 U.S. 202 , 211 ; Hill v.

Mercantile Nat'l Bank v. Commissioner

30 T.C. 84 · United States Tax Court · Apr 22, 1958

See Duffy v. Central R. Co., 268 U. S. 55 , 45 S. Ct. 429 , 69 L. Ed. 846 . In Hubinger v. Commissioner (C. C. … Burnet v. Sanford & Brooks Co., 282 U. S. 359 ; Putnam National Bank, 20 B. T. A. 45, aff'd. (C. A. 5) 50 F. 2d 158 ; Sneed v. Commissioner, (C. A. 5) 119 F. 2d 767, 771 , affirming 40 B. T.

Juvenile Shoe Corp. v. Commissioner

17 T.C. 1186 · United States Tax Court · Jan 17, 1952

The Juvenile Shoe Corporation of America, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Juvenile Shoe Corp. v. Commissioner Docket No. 21255 United States Tax Court 17 T.C. 1186 ; 1952 U.S. … As a whole, the facts in the instant case are more like those in Brown Shoe Co ., 45 B. T. A. 212 , affd. 133 F. 2d 582 .

O'Connor v. Commissioner

6 T.C. 323 · United States Tax Court · Feb 28, 1946

O'Connor, Petitioner, v. Commissioner of Internal Revenue, Respondent O'Connor v. Commissioner Docket No. 5792 United States Tax Court 6 T.C. 323 ; 1946 U.S. Tax Ct. … Petitioner argues we should reconsider the Smith case in the light of Bingham Trust v. Commissioner , 325 U.S. 365 .