Case law

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).

Kirchner, Moore & Co. v. Commissioner

54 T.C. 940 · United States Tax Court · May 7, 1970

In Nauts v. Slayton, 36 P. 2d 145 (C.A. 6, 1929), reversed and remanded sub nom. Denman v. … Pierce Corp. v. Commissioner, 120 F. 2d 206 (C.A. 5, 1941), affirming a Memorandum Opinion of the Board of Tax Appeals.

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.

Austin Co. v. Commissioner

71 T.C. 955 · United States Tax Court · Mar 5, 1979

Co. v. Commissioner, 126 F.2d 588 (2d Cir. 1942), affg. a Memorandum Opinion of the Board of Tax Appeals; Findley v. … Wilson Bros. & Co. v. Commissioner, 124 F.2d 606, 609 (9th Cir. 1941), affg. on this issue a Memorandum Opinion of the Board of Tax Appeals.

Roberts v. Commissioner

17 T.C. 1415 · United States Tax Court · Feb 29, 1952

Roberts and Florence V. Roberts, Petitioners, v. Commissioner of Internal Revenue, Respondent Roberts v. Commissioner Docket No. 24285 United States Tax Court 17 T.C. 1415 ; 1952 U.S. Tax Ct. … On December 26, 1944, the Corporation's board of directors, at a special meeting, voted to acquire from petitioner 500 shares of its capital stock.

Estate of Paxton v. Commissioner

86 T.C. 785 · United States Tax Court · Apr 28, 1986

Bank v. … Allard v. La Plain, 152 Wash. 211 , 277 P. 843 (1929); Van Stewart v. Townsend, 176 Wash. 311 , 28 P.2d 999 (1934); Carroll v. Carroll, 18 Wash.2d 171 , 138 P.2d 653 (1943); Jones v.

Sika Chemical Corp. v. Commissioner

64 T.C. 856 · United States Tax Court · Aug 7, 1975

Findley, 25 T.C. 311 , 318 (1955), affd. per curiam 236 F. 2d 959 (3d Cir. 1956); Wilson Bros. & Co. v. … In American Processing & Sales Co. v. United States, 371 F. 2d 842 (Ct.

Vose v. Commissioner

14 T.C. 113 · United States Tax Court · Jan 30, 1950

In Commissioner v. Estate of Church, 335 U. S. 632 , and Estate of Spiegel v. Commissioner, 335 U. … See John Wanamaker Philadelphia v. Commissioner, 139 Fed. (2d) 644, 646; United States v. Title Guarantee & Trust Co., 133 Fed. (2d) 990; and Brown Rogers-Dixon Co. v.

Stansbury v. Commissioner

104 T.C. 486 · United States Tax Court · Apr 18, 1995

See Great Western Sugar Co. v. KN Energy, Inc., supra at 274; Alfred Brown Co. v. Johnson-Gibbons & Reed, 695 P.2d 746, 749 (Colo. Ct. App. 1984). … See Alfred Brown Co. v. Johnson-Gibbons & Reed, supra at 749 . We have considered all other arguments made by petitioners and find them to be without merit.

Whittelsey, Inc. v. Commissioner

9 T.C. 700 · United States Tax Court · Oct 15, 1947

Ricaby Co. v. Nauts, 19 Fed. (2d) 271; see also George B. Ricaby Co., 1 B. T. … The Board denied personal service classification, but the Circuit Court allowed such classification.

Feller v. Commissioner

135 T.C. 497 · United States Tax Court · Nov 8, 2010

Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837 (1984). See sec. 7482(b)(2); Golsen v. Commissioner, 54 T.C. 742 (1970), affd. 445 F.2d 985 (10th Cir. 1971); Estate of Timken v. … See Estate of Capehart v. Commissioner, 125 T.C. 211, 224 (2005); Downing v. Commissioner, T.C. Memo. 2005-73 , supplementing T.C. Memo. 2003-347 ; Estate of Johnson v. Commissioner, T.C.

Yale Ave. Corp. v. Commissioner

58 T.C. 1062 · United States Tax Court · Sep 28, 1972

Warehouse Co. v. … We note that It ivas held in Bradford v.

Sproull v. Commissioner

16 T.C. 244 · United States Tax Court · Jan 30, 1951

Sproull, Petitioner, v. Commissioner of Internal Revenue, Respondent Sproull v. Commissioner Docket No. 25497 United States Tax Court 16 T.C. 244 ; 1951 U.S. Tax Ct. … of directors, petitioner was president of the board and held 1,375 shares of the corporate stock.

McCabe v. Commissioner

76 T.C. 876 · United States Tax Court · Jun 3, 1981

If petitioner had taken the bus to New York City, he would have boarded the bus at a stop located 2 blocks from his home in Suffern. … See Commissioner v. Flowers, 326 U.S. at 470, 472-474 ; Gilberg v. Commissioner, 55 T.C. at 614; Bunevith v.

Junior Miss Co. v. Commissioner

14 T.C. 1 · United States Tax Court · Jan 11, 1950

Commissioner v. Brouillard (C. C. A., 10th Cir.), 70 Fed. (2d) 154. … Commissioner v. Rector & Davidson (C. C. A., 5th Cir.), 111 Fed. (2d) 332; Commissioner v. Horseshoe Lease Syndicate (C. C. A. 5th Cir.), 110 Fed. (2d) 748; Pierre S. du Pont, 37 B. T. A. 1198, 1282; affd. (C. C.

Lansing Community Hotel Corp. v. Commissioner

14 T.C. 183 · United States Tax Court · Feb 13, 1950

Lansing Community Hotel Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Lansing Community Hotel Corp. v. Commissioner Docket No. 17760 United States Tax Court 14 T.C. 183 ; 1950 U.S. Tax Ct. … Justice Minton, said in Commissioner v. John Kelley Co . (C. C. A., 7th Cir.), , not "unusual today *301 for preferred stock to have a maturity or retirement date."

Singleton v. Commissioner

65 T.C. 1123 · United States Tax Court · Mar 18, 1976

The discovery was limited to the sole factual situation of showing whether the Commissioner’s examination of petitioner’s income tax returns resulted from a search of petitioner at Kennedy Airport as he boarded an airplane … Terry v. Ohio, supra at 21 . Therefore, the cases applying Terry v.

Holmes v. Commissioner

5 T.C. 1289 · United States Tax Court · Dec 21, 1945

Wells Fargo Bank & Union Trust Co. v. Commissioner ( Sternheim Estate ), 145 Fed. (2d) 132 ; Ithaca Trust Co. v. United States, supra . … See also United States v.

Iverson & Laux, Inc. v. Forrestal

6 T.C. 247 · United States Tax Court · Feb 25, 1946

Iverson & Laux, Inc., an Illinois Corporation, Petitioner, v. James Forrestal, Secretary of the Navy of the United States, Respondent Iverson & Laux, Inc. v. Forrestal Docket No. 300-R. … does not include any purchase order or agreement to furnish office supplies; or "(B) Any contract or arrangement other than a contract or arrangement between two contracting parties, one of which parties is found by the Board

Ye Mystic Krewe of Gasparilla v. Commissioner

80 T.C. 755 · United States Tax Court · Apr 25, 1983

The public were not permitted to board the vessel, but they were permitted to take photographs and view the ship from the pier without charge. … See and compare Scofield v. Corpus Christi Golf & Country Club, 127 F.2d 452 (5th Cir. 1942), and Koon Kreek Klub v. Thomas, 108 F.2d 616 (5th Cir. 1939), with United States v.