Case law

Perlmutter v. Commissioner

45 T.C. 311 · United States Tax Court · Dec 27, 1965

Euclid v. Ambler Co., 272 U.S. 365 (1926); City of Denver v. Knowles, 17 Colo. 544 , 30 Pac. 1041 (1892). … Co. v. Commissioner, 284 U.S. 552, 561 , 52 S. Ct. 211, 214 , 76 L. Ed. 484 . These observations can appropriately be applied to taxing acts. Old Colony R. Co. v. Commissioner, supra; De Ganay v.

Ryan School Retirement Trust v. Commissioner

24 T.C. 127 · United States Tax Court · Apr 29, 1955

They had applications pending before the Civil Aeronautics Board for permission to operate a feeder airline in California and an airline between Los Angeles and Hawaii. … Both applications were rejected by the Board in May 1946. On June 28, 1946, the Arizona School was dissolved.

Bunker Hill & Sullivan Mining & Concentrating Co. v. Commissioner

1 T.C. 1057 · United States Tax Court · May 11, 1943

The authorities referred to are Helvering v. Alabama Asphaltic Limestone Co., 315 U. S. 179 ; Palm Springs Holding Corporation v. Commissioner, 315 U. S. 185 ; and Helvering v. Southwest Consolidated Corporation, 315 U. … Treadwell Yukon received nothing, Hale v. Helvering, 85 Fed. (2d) 819; Bingham v. Commissioner, 105 Fed. (2d) 971; Commissioner v.

Poinier v. Commissioner

86 T.C. 478 · United States Tax Court · Mar 27, 1986

Stern, supra at 43 n. 3; Schuster v. … See Patterson v. Sims, 281 F.2d 577 (5th Cir. 1960); Mysse v. Commissioner, 57 T.C. 680, 703 (1972); Estate of Stein v. Commissioner, 37 T.C. 945, 959-962 (1962).

John Michael Dunkin v. Commissioner

124 T.C. No. 10 · United States Tax Court · Mar 31, 2005

Petitioner participated in a defined benefit pension plan (the pension plan) administered by the Board of Pension Commissioners (the pension board). … See In re Marriage of Brown, 544 P.2d 561 (Cal. 1976).

Mattox v. Commissioner

2 T.C. 586 · United States Tax Court · Aug 14, 1943

The question which we have to decide is one which has often troubled the Board of Tax Appeals, now the Tax Court of the United States, and likewise has troubled the Federal courts. … Some of these cases are Blair v. Commissioner, 300 U. S. 5 ; Helvering v. Eubank, 311 U. S. 122 ; Helvering v. Horst, 311 U. S. 112 ; Harrison v. Schaffner, 312 U. S. 579 .

Polster v. Commissioner

31 T.C. 874 · United States Tax Court · Jan 28, 1959

See, for example, Helvering v. Union Trust Co ., 125 F. 2d 401 , 404 . As was said in Pennsylvania Co. For Insurances, Etc. v. Brown , 6 F. … See Humes v. United States, supra ; Merchants Bank v. Commissioner , 320 U.S. 256 .

Smith v. Commissioner

3 T.C. 696 · United States Tax Court · May 1, 1944

Shaffner v. Lipinsky, 194 N. C. 1 ; 138 S. E. 418 ; Geneva Cooperage Co. v. Brown, 124 Ky. 16 ; 98 S. E. 279 . … Whether it was “ordinary,” or not, has been somewhat more difficult to determine. .The Supreme Court, in Welch v. Helvering, 290 U.

Annis Furs, Inc. v. Commissioner

2 T.C. 1096 · United States Tax Court · Nov 30, 1943

The respondent however, relying upon Gregory v. Helvering, 293 U. … Gregory v. Helvering, supra; DeNobili Cigar Co., 1 T. C. 673 .

Doriss v. Commissioner

3 T.C. 219 · United States Tax Court · Feb 7, 1944

Supp. 514 ; Irwin v. Larson, 94 Fed. (2d) 187. … Irwin v. Larson, supra. One reason why we are persuaded that our construction of the regulation is correct is that if it were construed otherwise a serious question would arise as to its validity. In Baldwin v.

R. R. Hensler, Inc. v. Commissioner

73 T.C. 168 · United States Tax Court · Oct 29, 1979

Deputy v. DuPont, supra. However, as said in Welch v. … The Board of Tax Appeals in Hubinger seemed to be distinguishing between ordinary and necessary expenses and capital expenditures.

McIver v. Commissioner

36 T.C.M. 719 · United States Tax Court · Jun 8, 1977

Petitioner was president, chairman of the board of directors, and sole shareholder of Jerco. Jerco was not a registered corporate real estate broker or salesman in Florida. … (That statement was also *272 signed by one Gilbert Brown on behalf of P.B.)

Benjamin v. Commissioner

66 T.C. 1084 · United States Tax Court · Sep 30, 1976

See, e.g., United States v. Davis, 397 U.S. 301 (1970); Ballenger v. … United States v. Davis, supra; Hasbrook v. United States, 343 F.2d 811 (2d Cir. 1965). See Bradbury v.

Calvert Anesthesia Assocs.-Pricha Phattiyakul v. Commissioner

110 T.C. 285 · United States Tax Court · Apr 27, 1998

Neilson v. Commissioner, 94 T.C. 1, 9 (1990); Naftel v. Commissioner, 85 T.C. 527, 529 (1985); see also sec. 7442. … See Insurance Corp. of Ireland, Ltd. v. Compagnie des Bauxites de Guiñee, 456 U.S. 694, 702 (1982); see also Brown v. Commissioner, 78 T.C. 215, 217-218 (1982), and the cases cited therein.

PPL Corp. & Subsidiaries v. Commissioner

135 T.C. 304 · United States Tax Court · Sep 9, 2010

SUBS. v. … Gordon Brown’s public statements in his July 2, 1997, Budget Speech, the Inland Revenue and U.K.

Barq's Bottling Co. v. Commissioner

5 T.C.M. 505 · United States Tax Court · Jun 21, 1946

Botany Worsted Mills v. United States, 278 U.S. 282 . … In support of this contention he relies upon such cases as Groves v. Commissioner, 99 Fed. (2d) 179 ; Griffiths v. Helvering, 308 U.S. 355 ; Higgins v. Smith, 308 U.S. 473 ; and Commissioner v.

Santa Anita Consol., Inc. v. Commissioner

50 T.C. 536 · United States Tax Court · Jul 2, 1968

See John Kelley Co. v. … Relying on United States v. Davis, 370 U.S. 65 (1962), and Welch v.

Hertig v. Commissioner

19 T.C. 109 · United States Tax Court · Oct 30, 1952

Ernest Rudolf Hertig, Petitioner, v. Commissioner of Internal Revenue, Respondent Hertig v. Commissioner Docket No. 28012 United States Tax Court 19 T.C. 109 ; 1952 U.S. Tax Ct. … Board and Lodging Employer agrees to furnish Employee with Board and Lodging during the term of this contract or cash allowance in lieu thereof at Employer's option. * * * * 15.

Albert v. Commissioner

13 T.C. 129 · United States Tax Court · Jul 22, 1949

Albert, Petitioner, v. Commissioner of Internal Revenue, Respondent Albert v. Commissioner Docket No. 19152 United States Tax Court 13 T.C. 129 ; 1949 U.S. Tax Ct. … The issue for decision is whether the Commissioner erred in disallowing a deduction of $ 717.91 claimed as ordinary and necessary expenses paid for traveling and board and lodging while away from home in pursuit of a trade

Hanover Ins. Co. v. Commissioner

65 T.C. 715 · United States Tax Court · Jan 7, 1976

State Board of Insurance v. Todd Shipyards Corp., 370 U.S. 451 (1962); United States v. Sylvanus, 192 F.2d 96 (7th Cir. 1951), cert. denied 342 U.S. 943 (1952). … Co. v.