Case law

Harvey v. Commissioner

10 T.C. 183 · United States Tax Court · Jan 30, 1948

Audio Gray Harvey, Petitioner, v. Commissioner of Internal Revenue, Respondent Harvey v. Commissioner Docket No. 10318 United States Tax Court 10 T.C. 183 ; 1948 U.S. Tax Ct. … He realized that the Selective Service Board might refuse to grant the deferment.

Sunbury Textile Mills, Inc. v. Commissioner

68 T.C. 528 · United States Tax Court · Jul 21, 1977

At a meeting of petitioner’s board of directors on March 4, 1969, the following two resolutions were unanimously approved by the board: Resolved, That management be authorized to purchase 72 OFS C & K shuttleless looms as … Estate of Craft v. Commissioner, 68 T.C. 249 (1977).

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.

Kolb v. Commissioner

5 T.C. 588 · United States Tax Court · Aug 13, 1945

Sanford's Estate v. Commissioner, 308 U. S. 39 ; Rasquin v. Humphreys, 308 U. S. 54 ; Smith v. Shaughnessy, 318 U. S. 176 ; Robinette v. Helvering, 318 U. S. 184 . … The Commissioner determined that the remainders were taxable; the Board of Tax Appeals reversed; the Circuit Court of Appeals for the Third Circuit reversed the Board of Tax Appeals; and the Supreme Court affirmed the Circuit

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.

Abingdon Potteries, Inc. v. Commissioner

19 T.C. 23 · United States Tax Court · Oct 10, 1952

True, petitioner’s board of directors had resolved on December 28,1944, to create such a trust, presumably to be patterned after a specimen instrument submitted to it, and had authorized a contribution of not to exceed $25,000 … Tavannes Watch Co. v. Commissioner, 176 F. 2d 211 (C. A. 2), reversing 10 T. C. 544 , also relied upon by petitioner, did not turn upon the issue decided herein. 1 Reviewed by the Court.

Joseph Amundsen & Anna Amundsen

United States Tax Court · Oct 3, 2023

Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). … 5 Public Company Accounting Oversight Board.

Estate of Iversen v. Commissioner

65 T.C. 391 · United States Tax Court · Nov 25, 1975

Fishman v. Fishman, 213 Pa. Super. 342 , 247 A. 2d 810 (1968); Marra v. Marra, 189 Pa. Super. 180 , 149 A. 2d 175 (1959); Commonwealth v. Rankin, 170 Pa. Super. 570 , 87 A. 2d 799 (1952); Drummond v. … See Dixon v. Commissioner, supra; Marra v. Marra, 170 Pa. Super. 588 , 88 A. 2d 112, 114 (1952).

Estate of Lowe v. Commissioner

64 T.C. 663 · United States Tax Court · Jul 28, 1975

See United States v. Wells, supra; Allen v. Trust Co., supra; Estate of Edward E. Ford, supra. Petitioners postulate two life-connected motives as impelling Lowe’s transfer in trust of January 12, 1967. … There is no indication of the frequency of the Areata board of directors meetings or of the nature of Lowe’s participation in them.

Diamond A Cattle Co. v. Commissioner

21 T.C. 1 · United States Tax Court · Oct 9, 1953

A. 880; Aluminum Castings Co. v. Boutzahn, 282 U. S. 92 . … See also Vermilya-Brown Co. v. Connell, 335 U. S. 377 ; United States v. Dickerson, 310 U. S. 554, 562 ; Haggar Co. v. Helvering, 308 U. S. 389 ; Gregory v. Helvering, 293 U. S. 465 ; Helvering v.

Estate of Piper v. Commissioner

72 T.C. 1062 · United States Tax Court · Sep 13, 1979

Bolles v. Commissioner, 69 T.C. 342 (1977); Hirsch v. Commissioner, 51 T.C. 121 (1968); Husted v. … In Bolles v.

Dielectric Materials Co. v. Commissioner

57 T.C. 587 · United States Tax Court · Feb 8, 1972

The aforementioned officers also constituted the petitioner’s board of directors during 1966. Issue 1. … Oswald Co. v.

Traxler v. Commissioner

61 T.C. 97 · United States Tax Court · Oct 25, 1973

Traxler, Petitioners v. Commissioner of Internal Revenue, Respondent Traxler v. Commissioner Docket No. 5089-73 United States Tax Court 61 T.C. 97 ; 1973 U.S. Tax Ct. LEXIS 35 ; 61 T.C. … To refute this argument the Board merely referred him to Webster's New International Dictionary (1924): "Mail, v.t.

Pomerantz v. Comm'r

90 T.C.M. 628 · United States Tax Court · Dec 22, 2005

Brown and petitioner regarding petitioner’s case. Mr. … Hoffman v. Commissioner, 119 T.C. 140, 145 (2002); Golden v. Commissioner, T.C. Memo. 2005-170.

Estate of Wood v. Commissioner

39 T.C. 919 · United States Tax Court · Mar 19, 1963

His salary at the sanitorium was originally $ 150 a month plus board and room, and it was gradually increased to $ 300 a month plus board and lodging. … In Henslee v.

Fuller v. Commissioner

9 T.C. 1069 · United States Tax Court · Dec 4, 1947

Deering v. Blair; Union Trust Co., Trustee, 18 B. T. A. 1234; affd., 54 Fed. (2d) 199; Louise Cheney, 22 B. T. A. 672; Thacher v. Lowe, 288 Fed. 994 . The petitioners cite A. R. R. 249, 3 C. B. 145. … The following'quotation from the opinion of the Board in that case is apposite: There is nothing in the terms of the trust agreement indicating that the farm should be operated on a commercial basis, except the fact that

Doyle v. Commissioner

3 T.C. 1092 · United States Tax Court · Jul 17, 1944

Doyle, Petitioner, v. Commissioner of Internal Revenue, Respondent Doyle v. Commissioner Docket No. 663 United States Tax Court 3 T.C. 1092 ; 1944 U.S. Tax Ct. … In 1922 Briggs & Turivas filed a claim for breach of contract with the United States Shipping Board, which was denied March 24, 1923.

Paschall v. Commissioner

137 T.C. 8 · United States Tax Court · Jul 5, 2011

V. … v.

Minnick v. Commissioner

14 T.C. 8 · United States Tax Court · Jan 11, 1950

In Seeber v. … See Jacobs v. Hoitt, supra; Salisbury v. Meeker, 152 Wash. 146 ; 277 Pac. 376 . In Jacobs v.

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.