Case law

Pullman, Inc. v. Commissioner

8 T.C. 292 · United States Tax Court · Feb 12, 1947

See Commissioner v. Bedford's Estate , 325 U.S. 283 ; A. J. Long, Jr ., 5 T. C. 327 ; affd., 155 Fed. (2d) 847 ; Kirschenbaum v. Commissioner , 155 Fed. (2d) 23 ; Bazley v. Commissioner , 155 Fed. (2d) 237 . … See also Flanagan v.

Horne v. Commissioner

5 T.C. 250 · United States Tax Court · Jun 15, 1945

Tax laws deal with realities (Helvering v. Security Savings & Commercial Bank, 72 F. (2d) 874 (C. C. A. 4) ; MacQueen & Co. v. Comm., 67 F. (2d) 857 (C. C. … A. 3)), and look at the entire transaction (cases just cited and Ahles Realty Corp. v. Comm., 71 F. (2d) 150 (C. C. A. 2)). Two very recent cases (Commissioner v. Dyer, 74 F. (2d) 685, and Marston v.

Paine v. Commissioner

63 T.C. 736 · United States Tax Court · Mar 31, 1975

[Edwards v. … Cleveland v. State, 438 S.W. 2d 807 (Tex. Crim. App. 1969); Womack v. State, 408 S.W. 2d 119 (Tex. Crim. App. 1967); Noblitt v. State, 103 Tex. Crim. 550 , 281 S.W. 849 (1926); Whitley v. State, 90 Tex.

Estate of Wetherill v. Commissioner

4 T.C. 678 · United States Tax Court · Jan 31, 1945

Van Fossan, Judge: The issue here is whether or not the estate’s right to a deduction under section 812 (d) of the Internal Revenue Code is defeated by the fact that the value of the gift to the Board of Regents of the University … For many years the leading and controlling case on this subject has been Ithaca Trust Co. v. United, States, 279 U. S. 151 .

Whistleblower 14106-10W v. Commissioner

76 A.L.R. Fed. 2d 713 · United States Tax Court · Dec 8, 2011

Cir. 1992) (upholding determination by Merit Systems Protection Board that employee was threatened with removal and unsatisfactory performance because disclosure of questionable employment practices); United States Merit … Litig., 732 F.2d 1302 , 1308 (7th Cir. 1984); Brown & Williamson Tobacco Corp. v. FTC, 710 F.2d 1165, 1178-1179 (6th Cir. 1983).

Kaufman v. Commissioner

55 T.C. 1046 · United States Tax Court · Mar 24, 1971

On November 17, 1965, the board of directors and shareholders of JJK adopted a plan of liquidation and dissolution for JJK. … Okonite Co. v. Commissioner (C.A. 3), 155 F. 2d 248, 250 , certiorari denied 329 U.S. 764 ; Thermoid Co. v. Commissioner (C.A. 3), 155 F. 2d 589, 590 ; Morainville v.

Estate of Steckel v. Commissioner

26 T.C. 600 · United States Tax Court · Jun 21, 1956

C. 682 , affd. 228 F. 2d 512 ; Shipp v. Commissioner, 217 F. 2d 401 , affirming a Memorandum Opinion of this Court dated June 15, 1953; E. W. Brown, 19 T. C. 87 , affirmed on this point 215 F. 2d 697 . … See dissenting opinion of Judge Frank in Hochchild v. Commissioner, (C. A. 2) 161 F. 2d 817, 819 .

Friedman v. Commissioner

37 T.C. 539 · United States Tax Court · Dec 22, 1961

Swenson v. Thomas, 164 F. 2d 783 -785 (C.A. 5, 1947). … Commissioner v. Flowers, 326 U.S. 465 (1946), rehearing denied 326 U.S. 812 .

Fried v. Commissioner

25 T.C. 1241 · United States Tax Court · Mar 15, 1956

Conrad v. Diehl, 344 Mo. 811 , 129 S. W. 2d 870 (1939). The Supreme Court of Missouri in Godchaux Sugars v. Quinn, 95 S. … (a) Borden of Proof. — In proceedings before the Board the burden of proof shall be upon the Commissioner to show that a petitioner is liable as a transferee of property of a taxpayer, but not to show that the taxpayer was

Haas v. United States

23 T.C. 892 · United States Tax Court · Feb 18, 1955

The War Contracts Price Adjustment Board determined that the admission of the new partners caused the dissolution of the partnership upon the admission of each. … Hoffman v. United States, 23 T. C. 569 . With respect to Haas Mold Company #2, the story is different.

Sebago Lumber Co. v. Commissioner

26 T.C. 1070 · United States Tax Court · Sep 19, 1956

See Moline Properties, Inc. v. Commissioner, 319 U. S. 436 (1943). In view of these facts, we hold that petitioner was a corporation during the years in issue. … Paramoumt-Richards Theatres v. Commissioner, 153 F. 2d 602, 604 (C. A. 5, 1946), affirming a Tax Court Memorandum Opinion.

BONNER v. COMMISSIONER

2004 T.C. Summary Opinion 34 · United States Tax Court · Mar 18, 2004

AND CELESTE BONNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2421-02S. Filed March 18, 2004. Louis Bonner, Jr. and Celeste Bonner, pro se. … Brown during 1999.

Peerless Weighing & Vending Machine Corp. v. Commissioner

52 T.C. 850 · United States Tax Court · Aug 21, 1969

Trust Co. v. Commissioner, 163 F. 2d 521 (C.A. 9, 1947), cited by us with approval in Trustee Corporation, supra. … In finding for the respondent, the Board stated ( 10 B.T.A. at 384 ): It seems unnecessary to cite authorities for the principle that a lessee under and by virtue of the terms of his lease acquires an interest in real estate

Elbert v. Commissioner

2 T.C. 892 · United States Tax Court · Oct 18, 1943

In Gooch Milling & Elevator Co. v. … In McEachern v. Rose, 302 U.

Stout v. Commissioner

71 T.C. 441 · United States Tax Court · Dec 27, 1978

Walsh v. United States, 322 F.Supp. 613, 619 (E.D.N.Y. 1970). In this case, the petitioner was not absent from work on account of personal injury or sickness. … See O’Neal v. United States, 314 F.Supp 383 (D.S.C. 1969). Respondent correctly disallowed the sick pay exclusion.

R. T. French Co. v. Commissioner

60 T.C. 836 · United States Tax Court · Sep 6, 1973

During the continuance of their joint venture in MPP, both Chivers and Reckitt & Colman Ltd. were represented on the MPP board of directors. … Co. v.

Frazier v. Commissioner

91 T.C. 1 · United States Tax Court · Jul 7, 1988

In an attempt to obtain petitioner’s social security number, Kunkle contacted the Internal Revenue Service (respondent) and the California Franchise Tax Board. … Riland v. Commissioner, 79 T.C. 185, 207 (1982); Greenberg’s Express, Inc. v. Commissioner, supra at 328; Suarez v.

Estate of Burdick v. Commissioner

96 T.C. 168 · United States Tax Court · Feb 4, 1991

In October of 1988, an attorney for decedent’s estate proposed to the board of directors of the First Church of Christ, Scientist, that the church’s remainder interest in decedent’s trust be terminated upon payment by the … See Flanagan v. United States, supra; First National Bank of Fayetteville v. United States, 727 F.2d 741 (8th Cir. 1984); Oetting v. United States, 712 F.2d 358 (8th Cir. 1983); Estate of Strock v.

Rojas v. Commissioner

90 T.C. 1090 · United States Tax Court · May 25, 1988

In Beauchamp & Brown Groves Co. v. … In Teget v. United States, 407 F. Supp. 681 (D.

Help Children, Inc. v. Commissioner

28 T.C. 1128 · United States Tax Court · Aug 30, 1957

The remaining contributions were made to the f ollowing institutions: [[Image here]] The corporation is governed by a nonpaid board of trustees who are elected by the membership. … Eaton Foundation v. Commissioner, 219 F. 2d 527 , affirming Memorandum Opinion of this Court; cf. United States v. Community Services, Inc., 189 F. 2d 421 , certiorari denied 342 U. S. 932 .