Case law

Deverna v. Comm'r

87 T.C.M. 1139 · United States Tax Court · Mar 22, 2004

Robert Brown (Brown) was the tax matters partner (TMP) for Manhattan Associates. … Lee v. Commissioner, supra at 149; Woodral v. Commissioner, 112 T.C. 19, 23 (1999). Petitioner contends that respondent “failed to perform the ministerial act of issuing an RAR to Mr.

Runyon v. Commissioner

8 T.C. 350 · United States Tax Court · Feb 19, 1947

See Commissioner v. Tower, 327 U. S. 280 ; Lusthaus v. Commissioner, 327 U. S. 293 ; Ed Dubinsky Durwood, 6 T. C. 682 ; Floyd D. Akers, 6 T. C. 693 ; Abe Schreiber, 6 T. C. 707 ; W. A. Belcher, 7 T. C. 182 ; and John G. … This court In Bozeman v.

Warren M. Goodspeed Scholarship Fund, Baybank Merchants, N.A. v. Commissioner

70 T.C. 515 · United States Tax Court · Jun 15, 1978

Elisian Guild, Inc. v. United States, 412 F.2d 121, 123-124 (1st Cir.). A simple reading of the will reveals quite clearly, we think, the purpose for which petitioner was established. … See sec. 1.509(a)-4(c)(3); sec. 1.501(cX3)-l(bXl)(m); Waller v. Commissioner, 39 T.C. 665, 674-675 .

Harrod v. Commissioner

20 T.C.M. 1544 · United States Tax Court · Oct 31, 1961

Harrod v. Commissioner. Harrod v. Commissioner Docket No. 81541. United States Tax Court T.C. Memo 1961-300 ; 1961 Tax Ct. Memo LEXIS 43 ; 20 T.C.M. (CCH) 1544 ; T.C.M. … Hill Co. v.

Graff v. Commissioner

74 T.C. 743 · United States Tax Court · Jul 21, 1980

Chrysler Corp. v. Brown, 441 U.S. 281, 311 (1979). … In Moser v.

Money v. Commissioner

89 T.C. 46 · United States Tax Court · Jul 6, 1987

Ballard v. Board of Trustees of Police Pension Fund, 263 Ind. 79 , 324 N.E.2d 813, 815-816 (1975); see also City of Greenwood v. Smith, 172 Ind. App. 552 , 361 N.E.2d 168 (1977). … Cook & Sons, Inc. v.

Lord v. Commissioner

1 T.C. 286 · United States Tax Court · Dec 16, 1942

Lord, Petitioner, v. Commissioner of Internal Revenue, Respondent. Phillips H. Lord, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Lord v. … On December 23, 1937, pursuant to resolutions adopted by its board of directors on the day preceding, the corporation created and established the Phillips H.

Perry v. Commissioner

54 T.C. 1293 · United States Tax Court · Jun 16, 1970

Knetsch v. United States, 364 U.S. 361 (1960). … Co. v.

Trustee Corp. v. Commissioner

42 T.C. 482 · United States Tax Court · Jun 2, 1964

In the fall of 1955 the board of directors of Glazer Steel Corp. included Guilford Glazer, Louis A. Glazer, Jerome S. Glazer, and Ida B. Glazer. … Wells Fargo Bank & Union Trust Co. v. Commissioner, (C.A. 9) 163 F. 2d 521 ; Laurene Walker Berger, 7 T.C. 1339 ; and Bernard A. Rosenblatt, 8 T.C. 1245 .

Kamins v. Commissioner

25 T.C. 1238 · United States Tax Court · Mar 15, 1956

Petitioner further relies upon Coughlin v. Commissioner, 203 F. 2d 307 , reversing 18 T. … C. 528 , where it was held that expenses for tuition, travel, board, and lodging, incurred by an attorney in attending a Federal taxation institute, were deductible as ordinary and necessary business expenes of his profession

Cummins-Collins Foundation v. Commissioner

15 T.C. 613 · United States Tax Court · Nov 15, 1950

Sheaffer Pen Co. v. Lucas , 41 Fed. (2d) 117 ; United States v. Phez Co ., 28 Fed. (2d) 106 ; Blackard v. Jones , 62 Fed. Supp. 234 . … Weyl v. Commissioner , 48 Fed. (2d) 811, 812 ; St. Louis Union Trust Co. v. Burnet , 59 Fed. (2d) 922, 926 .

Simplified Tax Records, Inc. v. Commissioner

41 T.C. 75 · United States Tax Court · Oct 17, 1963

In American Automobile Assn. v. … Brown v. Helvering, 291 U.S. 193 (1934).

Ad Investment 2000 Fund LLC, Community Media, Inc., A Partner Other Than the Tax Matters Partner v. Commissioner

142 T.C. No. 13 · United States Tax Court · Apr 16, 2014

Respondent seeks to compel the production of six opinion letters (opinions) from the law firm of Brown & Wood LLP. … In Cox v. Adm'r U.S.

Jackson v. Commissioner

59 T.C. 312 · United States Tax Court · Nov 27, 1972

On return from Tahiti, a Paramount film crew was on board, producing a film for television and a movie short entitled “Voyage from Tahiti.” This was done as a publicity stunt for Thane. … Furthermore, since Peter was Thane's regular captain, serving in that capacity in all but a few instances, we find that payments to Peter while not on board were appropriate.

Martin v. Commissioner

96 T.C. 814 · United States Tax Court · Jun 18, 1991

Knapp v. Commissioner, supra at 27. Similarly, in Estate of Hales v. … The Board of Tax Appeals found this loss to be a valuable right sufficient to render inapplicable the doctrine of constructive receipt. Estate of Hales v. Commissioner, supra at 1248.

Petaluma Co-Operative Creamery v. Commissioner

52 T.C. 457 · United States Tax Court · Jun 17, 1969

Did this stock dividend require a declaration of the board of directors? A, Tes. Q. … United States v. Haskel Engmeering & Supply Co., 880 F. 2d 786 (C.A. 9, 1967).

Funk v. Commissioner

14 T.C. 198 · United States Tax Court · Feb 14, 1950

In Funk v. … Funk v. Commissioner, Board of Tax Appeals (now the Tax Court of the United States) Docket No. 111193, hereinafter called the Wilfred J.

Rea v. Commissioner

60 T.C. 717 · United States Tax Court · Aug 20, 1973

See Shults Bread Co., 10 B.T.A. 268 (1928); Board of Tax Appeals v. United States ex rel.

Wrather v. Commissioner

14 T.C.M. 345 · United States Tax Court · Apr 26, 1955

John Wrather and Nell Wrather, Husband and Wife v. Commissioner. Wrather v. Commissioner Docket No. 38267. United States Tax Court T.C. Memo 1955-104 ; 1955 Tax Ct. Memo LEXIS 235 ; 14 T.C.M. (CCH) 345 ; T.C.M. … By January 1952, the Cooperative had received $130,000 from the Brown Lease and by June 1953, $167,500 from the Kieffer "A" Lease.

Allegheny Broadcasting Corp. v. Commissioner

12 T.C. 552 · United States Tax Court · Apr 4, 1949

Whether or not a corporation shall continue to exist as such is a matter wholly within the power of its stockholders and board of directors. … I think, also, that in principle the instant case is not distinguishable from Pepsi Cola Co. v. Commissioner, 155 Fed. (2d) 921.