Case law

Eisenberg v. Commissioner

5 T.C. 856 · United States Tax Court · Sep 28, 1945

Commissioner, 76 Fed. (2d) 520: and Burnet v. Leininger, 285 U. S. 136 . … Petitioners direct our attention to the fact that the judge of the Common Pleas Court approved reformed declarations of trust executed March 15,1943, “but as of January 2, 1940,” and they argue that under the doctrine of the Board

Osborne v. Commissioner

69 T.C.M. 1895 · United States Tax Court · Feb 14, 1995

Woody v. United States , 368 F.2d 668 (9th Cir. 1966) ; Brown v. Commissioner , supra ; Godwin v. United States , supra . Osborne was a member of ALPA, but Dawson was not. … Brown v. Commissioner , supra at 408 ; Hagar v. Commissioner , 43 T.C. 468 , 484 (1965) .

McCall v. Commissioner

27 T.C. 133 · United States Tax Court · Oct 31, 1956

Usibelli v. Commissioner, 229 F. 2d 539 (C. A. 9, 1955), affirming a Memorandum Opinion of this Court filed June 30, 1954. … Brown, 22 T. C. 58 (1954); and James Ruston, 19 T. C. 284 (1952).

Universal Steel Co. v. Commissioner

5 T.C. 627 · United States Tax Court · Aug 22, 1945

See Helvering v. National Grocery Co., 304 U. S. 282 , and many similar cases. In the numerous discussions and conclusions in cases of this character there is no set standard of measurement. … Decision will be entered v/nder Rule 60.

Metrocorp, Inc. v. Commissioner

116 T.C. 211 · United States Tax Court · Apr 13, 2001

See Leahy v. … The Federal Home Loan Bank Board (Bank Board) was an independent agency in the executive branch of the United States with broad discretionary powers over the Federal home loan bank system.

Daggitt v. Commissioner

23 T.C. 31 · United States Tax Court · Oct 13, 1954

Helvering v. Griffiths, supra; Helvering v. Sprouse and Strassburger v. Commissioner, both reported in 318 U. S. 604 . In the Griffiths case the Supreme Court felt that it was precluded from reexamining Eisner v. … We hold that Eisner v. Macomber is controlling here.

Becken v. Commissioner

5 T.C. 498 · United States Tax Court · Jul 27, 1945

A. 29; Raleigh v. United States, 5 Fed. Supp. 622. … Rogers, Brown & Crocker Bros., Inc., 32 B. T. A. 307. Petitioner is therefore entitled to a deduction of the amount of $892.61 in the computation of gross sales for the taxable year. American Lace Mfg. Co., 8 B. T.

Havey v. Commissioner

12 T.C. 409 · United States Tax Court · Mar 23, 1949

Havey, Petitioner, v. Commissioner of Internal Revenue, Respondent Havey v. Commissioner Docket No. 16165 United States Tax Court 12 T.C. 409 ; 1949 U.S. Tax Ct. … Held , expense of travel, board and room, and miscellaneous items at two resort hotels in New Jersey and at a ranch in Arizona incurred by petitioner and his wife, who had suffered a coronary occlusion approximately two years

Nordblom Associates, Inc. v. Commissioner

15 T.C. 220 · United States Tax Court · Sep 8, 1950

Nordblom Associates, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Nordblom Associates, Inc. v. Commissioner Docket No. 20425 United States Tax Court 15 T.C. 220 ; 1950 U.S. Tax Ct. … It is certain, so far as the record shows, that petitioner at no time *107 had any authority to act for Western since neither Western's board of directors nor any officer of that corporation acting on behalf of the board

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.

Mills v. Commissioner

3 T.C. 95 · United States Tax Court · Jan 21, 1944

Especially relied upon is Commissioner v. O. P. P. … See Commissioner v.

Martin Ice Cream Co. v. Comm'r

110 T.C. 189 · United States Tax Court · Mar 17, 1998

On June 15, 1988, the MIC board of directors, consisting of Arnold, Martin, and Mr. … Accordingly, as we noted in Alondra Indus., Ltd. v. Commissioner, T.C. Memo. 1996-32 , and Brown v. Commissioner, T.C.

Gregg Co. of Delaware v. Commissioner

23 T.C. 170 · United States Tax Court · Oct 29, 1954

The Gregg Company of Delaware, Petitioner, v. Commissioner of Internal Revenue, Respondent Gregg Co. of Delaware v. Commissioner Docket No. 46472 United States Tax Court 23 T.C. 170 ; 1954 U.S. Tax Ct. … The determination of the board of directors as to the surplus net earnings and income applicable to the payment of interest on the notes was to be final and conclusive.

Gordon v. Commissioner

63 T.C. 501 · United States Tax Court · Jan 30, 1975

Hill v. Philpott, 445 F. 2d 144 (C.A. 7, 1971); Vonder Ahe v. Howland (C.A. 9, 1973, 31 AFTR 2d 73-1075, 73-1 USTC par. 9333 ), reversing (N.D. Cal. 1971, 27 AFTR 2d 71-1176, 71-1 USTC par. 9315 ). … United States v. Blank, 459 F. 2d 383 (C.A. 6, 1972), certiorari denied 409 U.S. 887 (1972).

Estate of Marine v. Commissioner

97 T.C. 368 · United States Tax Court · Sep 23, 1991

The Board of Tax Appeals denied the estate’s claimed charitable deduction of such amount. … The decision of the Board is affirmed. [Knoernschild v. Commissioner, 97 F.2d at 215 .] The Seventh Circuit, in Knoernschild, relied upon Mississippi Valley Trust Co. v. Commissioner, 72 F.2d 197 (8th Cir. 1934).

Schmitt v. Commissioner

20 T.C. 352 · United States Tax Court · May 14, 1953

In Bass v. … In Eisner v. Macomber, 1920, 252 U. S. 189 , 40 S. Ct. 189 , 64 L. Ed. 521 , 9 A. L.

Ann Arbor Dog Training Club, Inc. v. Commissioner

74 T.C. 207 · United States Tax Court · Apr 29, 1980

Better Business Bureau v. United States, 326 U.S. 279, 283 (1945). … Although we need not follow respondent’s position as urged in his 1971 revenue ruling (see Browne v. Commissioner, 73 T.C. 723 (1980) (concurring opinion); Estate of Lang v.

Wichita Terminal Elevator Co. v. Commissioner

6 T.C. 1158 · United States Tax Court · May 24, 1946

Commissioner v. Court Holding Co., 324 U. S. 331 ; Meurer Steel Barrel Co. v. Commissioner, 144 Fed. (2d) 282; Taylor Oil & Gas Co. v. Commissioner, 47 Fed. (2d) 108; Hellebush v. … Walz v. Fidelity-Phoenix Fire Ins. Co. of New York, 10 Fed. (2d) 22; certiorari denied, 271 U. S. 665 ; Equipment Acceptance Corporation v. Arwood Can Mfg. Co., 117 Fed. (2d) 442; Hann v.

Grutman v. Commissioner

80 T.C. 464 · United States Tax Court · Feb 23, 1983

The lessee agreed to pay the lessor "rent” and "additional rent” equal to a proportionate share of the cash requirements of the lessor determined by the lessor’s board of directors. … See also Stiles v. Commissioner, T.C. Memo. 1981-711 ; Fisher v. Commissioner, T.C. Memo. 1970-255 . See also Stiles v. Commissioner, supra. See also Stiles v. Commissioner, supra; Fisher v. Commissioner, supra.

Keller v. Commissioner

77 T.C. 1014 · United States Tax Court · Oct 29, 1981

Justice Holmes, speaking for the Supreme Court in Klein v. Board of Supervisors, 282 U.S. 19, 24 (1930), about the nature of corporations: "But it leads nowhere to call a corporation a fiction. … Y.) v.