Case law

Larrabee v. Commissioner

33 T.C. 838 · United States Tax Court · Feb 9, 1960

We cannot say on the record before us that any of the claimed expenditures could qualify for deduction; accordingly, there is no occasion to make an approximation such as was indicated in Cohan v. … Although there was an incomplete list of guests who were on board the yacht in 1953, very few of them appear on this record to have been connected in any way with customers of the L. & F. Machine Co.

Kalchthaler v. Commissioner

7 T.C. 625 · United States Tax Court · Aug 20, 1946

Dyer v. Dyer, 194 S. E. 278 . … On the other hand, a decree of separation from bed and board authorizes a wife to live apart from her husband. See Words and Phrases, supra.

Moore v. Commissioner

1 T.C. 14 · United States Tax Court · Nov 12, 1942

S. 39 , and Rasquin v. Humphreys, 308 U. S. 54 . … They were decided before it was too late to proceed against the donee. • She also makes the further alternative contention that there was no gift of the income of the three trusts in 1932, 1933, or 1934, but the Board at

Estate of Horvath v. Commissioner

59 T.C. 551 · United States Tax Court · Jan 18, 1973

Mills v. … See Big “D” Development Corp. v. Commissioner, 453 F. 2d 1365 (C.A. 5, 1972), affirming a Memorandum Opinion of this Court; Mills v. Commissioner, supra; Manuel D.

International Flavors & Fragrances, Inc. v. Commissioner

62 T.C. 232 · United States Tax Court · May 16, 1974

National Carbide Corp. v. Commissioner, 336 U.S. 422 (1949); Moline Properties v. Commissioner, 319 U.S. 436 (1943). … Commissioner v. Brown, 380 U.S. 563 (1965); Helvering v. Flaccus Leather Co., 313 U.S. 247 (1941).

Ciaio v. Commissioner

47 T.C. 447 · United States Tax Court · Jan 31, 1967

In Erickson v. United States, 189 F. … Fox v. Harrison, 7 Cir., 145 F. 2d 521, 522 . To the same effect see Milton F.

Pankratz v. Commissioner

22 T.C. 1298 · United States Tax Court · Sep 30, 1954

Pankratz, Petitioners, v. Commissioner of Internal Revenue, Respondent Pankratz v. Commissioner Docket No. 45848 United States Tax Court 22 T.C. 1298 ; 1954 U.S. Tax Ct. … Norris and Florence V. Norris.

Metropolitan Bldg. Co. v. Commissioner

31 T.C. 971 · United States Tax Court · Feb 11, 1959

Commissioner v. P. G. Lake, Inc., supra; Helvering v. Horst, 311 U.S. 112 (1940); Commissioner v. Starr Brothers, Inc., 204 F. 2d 673 (C.A. 2, 1953), reversing 18 T.C. 149 (1952); Commissioner v. … Bespondent also relies on Commissioner v.

Holmes Enterprises, Inc. v. Commissioner

69 T.C. 114 · United States Tax Court · Oct 26, 1977

See Brown v. Commissioner, 215 F.2d 697 (5th Cir. 1954), affg. on this point 19 T.C. 87 (1952). The legal fees of $3,000 deducted by petitioner should have been capitalized. … Fuller v. Commissioner, supra; Holt v. Commissioner, supra; Mazzei v. Commissioner, supra; Richey v. Commissioner, supra. In Holt v.

Whitfield v. Commissioner

14 T.C. 776 · United States Tax Court · May 9, 1950

Whitfield, Jr., Executors, Alleged Transferree of Whitfield Realty Company, Petitioners, v. Commissioner of Internal Revenue, Respondent Whitfield v. … of Directors and perform any other duties imposed upon him by the Board of Directors. 8.

United California Bank v. Commissioner

41 T.C. 437 · United States Tax Court · Jan 3, 1964

Beus v. Commissioner, 261 F. 2d 176 , affirming 28 T.C. 1133 ; Talache Mines v. United States, 218 F. 2d 491 . Mere nonuse of the property is not sufficient. Beus v. … Also according to the minutes, “the Chairman expressed the view, concurred in by the Board, that the approval by this Board to the extension of option was also approval by this Board of the action of the officers in abandoning

Carlisle v. Commissioner

37 T.C. 424 · United States Tax Court · Dec 11, 1961

Carlisle, Petitioners, v. Commissioner of Internal Revenue, Respondent Carlisle v. Commissioner Docket No. 86711 United States Tax Court 37 T.C. 424 ; 1961 U.S. Tax Ct. … This board determined that petitioner was fit for active duty.

Ivey Branch Holdings, LLC, Ivey Branch Investors, LLC, Tax Matters Partner

United States Tax Court · Jun 9, 2025

Brown for review. Later that day Ms. Brown replied by email that she had “added the penalties to the [Form] 4605-A and a reference to the F[orm] 886-A in the remarks section.” … See Goddard v. Commissioner, T.C. Memo. 2022-96, 124 T.C.M. (CCH) 187, 197. And Ms. Brown was not a member of the exam- ination team, but a TEFRA Coordinator who supplied technical advice relating to TEFRA partnerships.

Kerman v. Comm'r

101 T.C.M. 1241 · United States Tax Court · Mar 8, 2011

Edwards v. Commissioner, T.C. Memo. 2002-169 (citing Pasternak v. Commissioner, supra at 903, Elliott v. … Petitioners did not read the Brown & Wood tax opinion.

Leavell v. Commissioner

104 T.C. 140 · United States Tax Court · Jan 30, 1995

Sargent v. … Sargent v.

Love v. Commissioner

8 T.C. 400 · United States Tax Court · Feb 24, 1947

Ralph Love, Petitioner, v. Commissioner of Internal Revenue, Respondent Love v. Commissioner Docket No. 9445 United States Tax Court 8 T.C. 400 ; 1947 U.S. Tax Ct. … A Well, that depended on the draft board -- requesting a renewal, you mean? Q Yes.

Greene v. Comm'r

2010 T.C. Summary Opinion 66 · United States Tax Court · Jun 1, 2010

Rule 142(a)(1); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S. 111, 115 (1933). … See Knudsen v. Commissioner, 131 T.C. 185, 185-189 (2008); Cyman v. Commissioner, T.C. Memo. 2009-144.

Estate of Orphanos v. Commissioner

67 T.C. 780 · United States Tax Court · Feb 9, 1977

Fitschen v. United States Trust Co., 233 S.W.2d 405 (Ky. 1950); Harrison v. Shippen, 419 S.W.2d 557 (Ky. 1967); Graham v. Jones, 386 S.W.2d 271 (Ky. 1965); Harlan National Bank v. … Brown, 317 S.W.2d 903 (Ky. 1958); McCray v. Long, 303 S.W.2d 296 (Ky. 1957). Furthermore, the "testator’s intent should be determined from what he says” in the whole will. University of Louisville v. Liberty Nat.

Philadelphia-Baltimore Stock Exchange v. Commissioner

19 T.C. 355 · United States Tax Court · Nov 28, 1952

Philadelphia-Baltimore Stock Exchange (Formerly Philadelphia Stock Exchange), Petitioner, v. Commissioner of Internal Revenue, Respondent Philadelphia-Baltimore Stock Exchange v. … In 1944 the trustees consisted of the president, vice president, and three other members of petitioner appointed by its board of governors.

Estate of Stoll v. Commissioner

38 T.C. 223 · United States Tax Court · May 9, 1962

Gould v. Gould, 245 U.S. 151 ; Mead Corporation v. Commissioner, 116 F. 2d 187 ; Uhl Estate Co. v. Commissioner, 116 F. 2d 403 . … In Jorgensen v. United States, 152 F.