Case law

Alabama Coca-Cola Bottling Co. v. Commissioner

28 T.C.M. 635 · United States Tax Court · Jun 18, 1969

Perkins, Trustee for Martha Brown Edmondson Martha was the sister of Blanche 40 40 40 Lucia E. Perkins Niece of Martha Brown Edmondson and Blanche 180 180 180 Charles V. … Crawford *191 Rainwater (hereinafter referred to as Crawford) is the son of Charles V. Rainwater who was chairman of the Board of Hygeia during the years here in issue.

Crystal Star Eagle v. Comm'r

2001 U.S. Tax Ct. LEXIS 60 · United States Tax Court · Dec 7, 2001

AMARNICK, DECEASED, AARON AMARNICK, PERSONAL REPRESENTATIVE, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent Crystal Star Eagle v. … Brown, Margaret C. Brown , Donald M. Browning, Jr., Donald M. Browning, Sr., Edith D. Browning, Sr., James R. Browning, Charlene R. Browning, David A. Clark, Terice B. Clark, Jay E. Frieling, Shirley M.

Safeguard Mutual Fire Insurance v. Commissioner

4 T.C. 75 · United States Tax Court · Sep 29, 1944

We think that petitioner was a mutual insurance company other than life as that term has been interpreted and construed by the Board of Tax Appeals and the courts. … See Keystone Mutual Casualty Co. v. Driscoll, supra.

Eastern Color Printing Co. v. Commissioner

63 T.C. 27 · United States Tax Court · Oct 21, 1974

The Court of Claims in Movielab, Inc. v. … See Davant v. Commissioner, 366 F. 2d 874, 879 (C.A. 5, 1966), modifying 43 T.C. 540 (1965); Estate of Stauffer v.

Rockford Screw Products Co. v. Commissioner

21 T.C. 834 · United States Tax Court · Feb 26, 1954

REVIEW OP ABNORMALITIES BY BOARD OP TAX APPEALS. … REVIEW OF ABNORMALITIES BY BOARD OF TAX APPEALS.

Wisconsin Electric Power Co. v. Commissioner

18 T.C. 400 · United States Tax Court · May 23, 1952

Commissioner v. Dashiell, 100 F. 2d 625 , affirming 36 B. T. A. 313. … The Wisconsin Board of Tax Appeals allowed the petitioner a deduction for 1942 representing its loss on all of the land sold in that year.

Hamilton v. Commissioner

34 T.C. 927 · United States Tax Court · Aug 31, 1960

William Thomas Hamilton, Petitioner, v. Commissioner of Internal Revenue, Respondent Hamilton v. Commissioner Docket No. 83907 United States Tax Court 34 T.C. 927 ; 1960 U.S. Tax Ct. … Held , board and lodging furnished by taxpayer to another adult in return for services, either present or future, constitutes remuneration and not "support" within the meaning of section 152 (a)(9), I.R.C. 1954 .

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 .

Estate of Pfohl v. Commissioner

70 T.C. 630 · United States Tax Court · Aug 7, 1978

Morgan v. Commissioner, 309 U.S. 78, 80 (1940); Aldrich v. United States, 346 F.2d 37 (5th Cir. 1965); Estate of Hoenig v. … Teachers’ Retirement Board of New York, supra; Williston, supra at sec. 253. Cf. Estate of Dreyer v. Commissioner, 68 T.C. 275 (1977). The right of disaffirmance does not extend to the other party to the contract.

Roberts v. Commissioner

10 T.C. 581 · United States Tax Court · Mar 31, 1948

We have examined Herbert's Laurel-Ventura v. Laurel Ventura Holding Corporation, 138 Pac. (2d) 43 , and Anders v. State Board of Equalization, 185 Pac. (2d) 883 (both from California courts), though they were not cited.

Luehrmann v. Commissioner

33 T.C. 277 · United States Tax Court · Nov 18, 1959

Black's Law Dictionary (4th ed.); Nichols v. Swickard , 211 Iowa 957 , 234 N.W. 846 , 847 . See also In re Cushman's Estate , 143 Misc. 432 , 257 N.Y. Supp. 582 , 586 ; Brown v. … of Roy & Titcomb, Inc. v.

Culhane v. Commissioner

31 T.C. 758 · United States Tax Court · Jan 22, 1959

Culhane, Petitioners, v. Commissioner of Internal Revenue, Respondent Culhane v. Commissioner Docket No. 57573 United States Tax Court 31 T.C. 758 ; 1959 U.S. Tax Ct. … At a meeting of the board of directors of Wilmington held on July 28, 1949, at 2 p.m., the entire board of directors, consisting of Alexandrine, Lammot duPont, Jr., and Ann J.

Wilputte Coke Oven Corp. v. Commissioner

10 T.C. 435 · United States Tax Court · Mar 16, 1948

This determination was sustained by the Board of Tax Appeals and by the Circuit Court. … Chattanooga Savings Bank v. Brewer, 17 Fed. (2d) 79; certiorari denied, 274 U. S. 751 ; Christopher v. Burnet, 55 Fed. (2d) 527, affirming 13 B. T. A. 729; Anketell Lumber & Coal Co. v. United States, 1 Fed.

Colorado County Federal Sav. & Loan Asso. v. Commissioner

36 T.C. 1167 · United States Tax Court · Sep 29, 1961

Colorado County Federal Savings and Loan Association, Petitioner, v. Commissioner of Internal Revenue, Respondent Colorado County Federal Sav. & Loan Asso. v. … Petitioner places reliance upon a resolution adopted by its board of directors on May 8, 1957. This resolution is set out in our summary of the facts above stated.

Gruen v. Commissioner

1 T.C. 130 · United States Tax Court · Nov 24, 1942

The elements essential for a valid gift are to be found in the following statement from Edson v. … See United States v. Klausner, 25 Fed. (2d) 608. Decisions will be entered wider Rule 50.

Sinclaire v. Commissioner

13 T.C. 742 · United States Tax Court · Nov 14, 1949

Commissioner v. Chase National Bank of New York, 82 Fed. (2d) 157; certiorari denied, 299 U. S. 552 ; Holderness v. Commissioner, 86 Fed. (2d) 137; Checkering v. … S. 636 ; Brown v. Commissioner, 119 Fed. (2d) 983; Millard v. Maloney, 121 Fed. (2d) 257; certiorari denied, 314 U. S. 636 .

Grabien v. Commissioner

48 T.C. 750 · United States Tax Court · Aug 24, 1967

Brown, Jr., 19 T.C. 87 (1952), affd. 215 F. 2d 697 (C.A. 5, 1954) ; Sturgeon v. McMahon, 155 F. Supp. 628 (S.D. N.Y. 1957), affirmed per curiam 255 F. 2d 685 (C.A. 2, 1958).

Estate of Brandon v. Commissioner

86 T.C. 327 · United States Tax Court · Mar 10, 1986

In addition, decedent was a member of the board of directors of the Helena “Rice Dryer” board which was in the midst of a $1.3-million lawsuit. … Estate of Barrett v.

Click v. Commissioner

78 T.C. 225 · United States Tax Court · Feb 16, 1982

Wagensen v. Commissioner, 74 T.C. 653, 660 (1980); Biggs v. Commissioner, 69 T.C. 905, 914 (1978). The petitioner bears the burden of proving that she had the requisite investment intent. Regals Realty Co. v. … Approximately 2 weeks later, the corporation’s board of directors decided to liquidate and sell the property.

Heuer v. Commissioner

32 T.C. 947 · United States Tax Court · Jul 23, 1959

The affairs of the association are governed by a board of directors consisting of five shareholders elected each year. … Irby, Jr., 30 T.C. 1166 , on appeal (C.A. 5); Patchen v. Commissioner, (C.A. 5) 258 F. 2d 544 , affirming on this issue 27 T.C. 592 ; Hansen v.