Case law

Stahl v. Commissioner

22 T.C.M. 996 · United States Tax Court · Jul 29, 1963

Brown, supra ; Anderson Dairy, Inc., supra ; Royal Farms Dairy Co., supra; Union Bank v. United States, supra ; cf. Estate of Ernest G. Howes, 30 T.C. 909 (1958) , affirmed sub nom. Commissioner v. … Brown, supra ; Anderson Dairy, Inc., supra ; Royal Farms Dairy Co., supra; Union Bank v. United States, supra. Respondent's reliance here on Emanuel N.

Hodges v. Commissioner

63 T.C.M. 3198 · United States Tax Court · Jun 29, 1992

HODGES, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Hodges v. … Collins v. Commissioner , 857 F.2d 1383 (9th Cir. 1988) , affg. Dister v. Commissioner , T.C. Memo. 1987-217 ; Sochin v. Commissioner , 843 F.2d 351 , 354 (9th Cir. 1988) , *445 affg. Brown v.

Schalk Chemical Co. v. Commissioner

32 T.C. 879 · United States Tax Court · Jul 9, 1959

Paramount-Richards Theatres, Inc. v. … See Vance v. Roberts , 93 Fla. 379 , 118 So. 205 ; Wright v. Suydam , 72 Wash. 587 , 131 Pac. 239 ; and cf. Rodriguez v. Barnett , 333 P. 2d 407 (Cal. App. 1958) .

Eres v. Commissioner

23 T.C. 1 · United States Tax Court · Oct 6, 1954

George Eres, Petitioner, v. Commissioner of Internal Revenue, Respondent Eres v. Commissioner Docket No. 29800 United States Tax Court 23 T.C. 1 ; 1954 U.S. Tax Ct. … Green attended a meeting of the board of directors of Ris corporation, as petitioner's proxy, on October 19, 1945.

William L. Powell Foundation v. Commissioner

21 T.C. 279 · United States Tax Court · Nov 23, 1953

Powell Foundation, Petitioner, v. Commissioner of Internal Revenue, Respondent William L. Powell Foundation v. Commissioner Docket No. 35422 United States Tax Court 21 T.C. 279 ; 1953 U.S. Tax Ct. … Darnall (hereinafter referred to as Darnall), his close friend and business advisor, and the Board of the Church.

Hornaday v. Commissioner

81 T.C. 830 · United States Tax Court · Nov 7, 1983

Petitioner, who was 85 years old at the time of trial herein, was the chief executive officer of Guilford Mills until 1968 when he became chairman of the board of that company. … Petitioner continued to preside as chairman of the board of Guilford Mills until March 1971, when he terminated his active employment with that company through retirement.

Metzger v. Commissioner

88 T.C. 834 · United States Tax Court · Apr 9, 1987

Continuous tenure shall be granted only by action of the Board of Trustees upon the recommendation of the President. … In Bent v.

Young Motor Co. v. Commissioner

32 T.C. 1336 · United States Tax Court · Sep 30, 1959

An understandable confusion, see Casey v. Commissioner, (C.A. 2) 267 F. 2d 26 , reversing T.C. … See Helvering v. Nat. Grocery Co., 304 U.S. 282 ; Helvering v. Stock Yards Co., supra. No dividends have ever been paid by petitioner over its 20-odd-year history.

Humphrey v. Commissioner

5 T.C.M. 21 · United States Tax Court · Jan 18, 1946

Humphrey v. Commissioner. Laura Brown Waggoner, Formerly Laura Humphrey v. Commissioner. Albert Patterson Humphrey Deceased v. Commissioner. Irene Humphrey v. Commissioner. Layton Humphrey v. Commissioner. Joe A. … Browning's note for $8,500 in 1941 established their claim to a deduction at that time. Such might be the case if their own claim was then uncollectible. Shiman v. Commissioner (C.C.A., 2nd Cir.). 60 Fed. (2d) 65 .

Kelly v. Commissioner

23 T.C. 682 · United States Tax Court · Jan 24, 1955

Garrett v. Crenshaw, 196 F. 2d 185 ; Bowers v. Lumpkin, 140 F. 2d 927 ; E. W. Brown, Jr., 19 T. C. 87 , affirmed as to this point (C. A. 5) 215 F. 2d 697 ; Virginia Hansen Vincent, 18 T. C. 339 , on appeal (C.A.9). … Addison v. Commissioner, 177 F. 2d 521 .

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.

Hoffman v. United States

23 T.C. 569 · United States Tax Court · Dec 31, 1954

Warner v. War Contracts Price Adjst. Board, 14 T. C. 1320 (1950). Upon the record before us, we have found as a fact that petitioner and the Corporation were under common control. … Moening v. War Contracts Price Adjustment Board, 14 T. C. 589 (1950).

Hilton v. Commissioner

13 T.C. 623 · United States Tax Court · Oct 24, 1949

Hilton, Petitioners, v. Commissioner of Internal Revenue, Respondent Hilton v. Commissioner Docket No. 18287 United States Tax Court 13 T.C. 623 ; 1949 U.S. Tax Ct. … In support of his contention respondent cites Commissioner v. Court Holding Co ., 324 U.S. 331 ; Griffiths v. Commissioner , 308 U.S. 355 ; Higgins v. Smith , 308 U.S. 473 ; Minnesota Tea Co. v.

Rieben v. Commissioner

8 T.C. 359 · United States Tax Court · Feb 19, 1947

Levey v. Helvering, supra . … Lucas v. Earl , 281 U.S. 111 ; Burnet v. Leininger , 285 U.S. 136 ; Helvering v. Eubank , 311 U.S. 122 ; Helvering v.

Koehn v. Commissioner

16 T.C. 1378 · United States Tax Court · Jun 19, 1951

Koehn, Petitioner, v. Commissioner of Internal Revenue, Respondent Koehn v. Commissioner Docket No. 26575 United States Tax Court 16 T.C. 1378 ; 1951 U.S. Tax Ct. … A. 338 , in which the Board of Tax Appeals held that gambling losses may be offset against gambling gains in determining gross income.

Segal v. Commissioner

36 T.C. 148 · United States Tax Court · Apr 24, 1961

Segal v. Michel M. Segal, No. 24,220. … Petitioner paid Joel’s tuition during this period and in addition sent him $30 per week to be used for his allowance, room and board, and miscellaneous school expenses.

Nellie Callahan Scholarship Fund v. Commissioner

73 T.C. 626 · United States Tax Court · Jan 3, 1980

Goodspeed Scholarship Fund v. Commissioner, supra. … Goodspeed Scholarship Fund v. Commissioner, supra.

First Nat'l Bank v. Commissioner

44 T.C. 764 · United States Tax Court · Aug 30, 1965

Brown v. Helvering, 291 U.S. 193 (1934), and this was true originally as to bad debts. … Miners National Bank of Wilkes-Barre, supra; American State Bank v. United States, supra; Union National Bank of Youngstown v. United States, supra; North Carolina National Bank v. United States, 345 F. 2d 544 (Ct.

L. Heller & Son, Inc. v. Commissioner

12 T.C. 1109 · United States Tax Court · Jun 22, 1949

Heller and Son, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent L. Heller & Son, Inc. v. Commissioner Docket No. 18987 United States Tax Court 12 T.C. 1109 ; 1949 U.S. Tax Ct. … The theory that these were capital expenditures is disposed of in the following language in Harris & Co. v.

Bowen v. Commissioner

78 T.C. 55 · United States Tax Court · Jan 20, 1982

Quoting Griffiths v. … In Sun Properties v.