Case law

Chronicle Publishing Co. v. Commissioner

67 T.C. 964 · United States Tax Court · Mar 21, 1977

Equitable Publishing Co. v. Commissioner, 356 F.2d 514 (3d Cir. 1966). … Those decisions (United States v. Southwestern Cable Co., 392 U.S. 157 (1968), and Fortnightly Corp. v.

W. Tip Davis Co. v. Patterson

12 T.C. 335 · United States Tax Court · Mar 10, 1949

The respondent relies upon Standard Oil Co. of California v. Johnson, 316 U. S. 481 , in which the Court stated that post exchanges “are integral parts of the War Department.” … The Joint Renegotiation Manual, covering fiscal years ended before July 1,1943, secs. 332.5 and 332.6; Renegotiation Regulations, War Contracts Price Adjustment Board, applicable to fiscal years ending after June 30, 1943

Houg v. Commissioner

54 T.C. 792 · United States Tax Court · Apr 20, 1970

Houg, Petitioners v. Commissioner of Internal Revenue, Respondent Houg v. Commissioner Docket No. 2393-67 United States Tax Court 54 T.C. 792 ; 1970 U.S. Tax Ct. … Also each member received a letter after the *171 merger from the Advisory Board of the Amended Plan dated May 20, 1963, in which the board explained the effect of the amendment and recommended that the employees not withdraw

Ross v. Commissioner

38 T.C. 309 · United States Tax Court · May 22, 1962

United States v. O'Connor, 291 F. 2d 520 , 525 (C.A. 2). … This Board of course has no power to adopt a construction at variance with the meaning which the legislature apparently intended. Bowers V. New York & Albany Lighterage Co., 273 U.S. 346 .” See also Louis H.

Giddio v. Commissioner

54 T.C. 1530 · United States Tax Court · Jul 27, 1970

In Bishoff v. … In Fiorella v.

Corn Products Co. v. Commissioner

36 T.C. 969 · United States Tax Court · Sep 13, 1961

In this form it is a fine, white to light brown powder with varying characteristics suitable for its intended uses. … The minutes of meetings of petitioner’s advisory board held in 1939 and 1940 show that the matter of increasing the production of Cere-lose was considered and rejected.

International State Bank v. Commissioner

70 T.C. 173 · United States Tax Court · May 8, 1978

See, e.g., Yoc Heating Carp. v. Commissioner, 61 T.C. 168, 178 (1973); Cabax Mills v. Commissioner, 59 T.C. 401, 409 (1972); Kansas Sand & Concrete, Inc. v. … Cabax Mills v. Commissioner, supra; see Kansas Sand & Concrete, Inc. v. Commissioner, supra.

Rose v. Commissioner

36 T.C.M. 1134 · United States Tax Court · Aug 23, 1977

Brown, mailed a notice of deficiency to petitioner on March 30, 1976. … DeWelles v.

Rosenzweig v. Commissioner

1 T.C. 24 · United States Tax Court · Nov 13, 1942

The Board held that the amounts received by him were not compensation received for personal services rendered. … See Sabatini v. Commissioner (C. C. A., 2d Cir.), 98 Fed. (2d) 753; Irving Berlin, 42 B. T. A. 668. Decision will be entered for the respondent in Docket No. 108342 and under Bule 50 in Docket No. 108343.

Terry T. Brown, Sr.

United States Tax Court · Jan 26, 2021

BROWN, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5687-16S. Filed January 26, 2021. Terry T. Brown, Sr., pro se. … In support of his position, petitioner submitted a letter from a former BBH board member.

Frank v. Commissioner

2 T.C. 1157 · United States Tax Court · Dec 17, 1943

The Board, noting that the income was subject to taxpayer’s command at all times, sustained the Commissioner’s determination that such income was currently distributable and taxable to the taxpayer. Cf. Harrison v. … S. 579 ; Helvering v. Horst, 311 U. S. 112 ; Helvering v. Eubank, 311 U. S. 122 .

Kellems v. Commissioner

58 T.C. 556 · United States Tax Court · Jun 27, 1972

Bolling v. Sharpe, 347 U.S. 497 (1954); Shapiro v. Thompson, 394 U.S. 618, 642 (1969). … McDonald v. Board of Election Comm’rs, 394 U.S. 802, 809 (1969), McGowan v. Maryland, 366 U.S. 420, 426 (1961), Standard Oil Co. v.

Juniata Farmers Co-op. Ass'n v. Commissioner

43 T.C. 836 · United States Tax Court · Mar 22, 1965

Pomeroy Cooperative Grain Co. v. Commissioner, 288 F. 2d 326 . … Brown v. Helvering, 291 U.S. 193 ; David J. Joseph Co. v. Commissioner, 136 F. 2d 410 , affirming a Memorandum Opinion of this Court. We sustain respondent on this issue. Decision will be entered under Bvile 50.

Keene v. Commissioner

38 T.C.M. 553 · United States Tax Court · Mar 29, 1979

for Governor; (3) Cranston for Senator; (4) California's Proposition 14, and (5) Jones for Board of Education. … Kwong v. Commissioner, 65 T.C. 959 , 967 (1976) . Issue 2. Media and Supplies Expense Associates recorded as income in 1962 $100,968.35, attributable to the Governor Brown re-election campaign.

Carter v. Commissioner

17 T.C. 994 · United States Tax Court · Dec 13, 1951

Jean Laing Carter, Petitioner, v. Commissioner of Internal Revenue, Respondent. L. L. Carter, Petitioner, v. Commissioner of Internal Revenue, Respondent Carter v. … Rogan v. Delaney , 110 F. 2d 336 , certiorari denied, 311 U.S. 660 ; Sara R. Preston , 35 B. T. A. 312 .

Young v. Commissioner

5 T.C. 1251 · United States Tax Court · Dec 13, 1945

Helvering v. Clifford, supra; Stockstrom v. Commissioner, 148 Fed. (2d) 491; Funsten v. Commissioner, 148 Fed. (2d) 805; Edison v. Commissioner, 148 Fed. (2d) 810; Anna Morgan, 5 T. C. 1089 . … The court, in affirming the Board of Tax Appeals, said that the excess of value over the purchase price was taxable income to the stockholders under the statutes and regulations.

Bartel v. Commissioner

54 T.C. 25 · United States Tax Court · Jan 14, 1970

Irving Bartel and Elaine Melman Bartel, Petitioners v. Commissioner of Internal Revenue, Respondent Bartel v. Commissioner Docket No. 1750-67 United States Tax Court 54 T.C. 25 ; 1970 U.S. Tax Ct. … However, by action of the board of directors on July 1, 1952, reaffirmed by the board on January 6, 1954, the petitioner accepted a reduction in his salary, but it was provided that the board of directors could, in its discretion

Aronson v. Commissioner

98 T.C. 283 · United States Tax Court · Mar 18, 1992

Morgan v. Commissioner, 309 U.S. 78, 80 (1940); Lyeth v. Hoey, 305 U.S. 188, 193 (1938); Heiner v. Mellon, 304 U.S. 271, 279 (1938); Burnet v. Harmel, 287 U.S. 103, 110 (1932). … The IRS issued a letter ruling to the Maryland State retirement and pension systems board of trustees.

Charles Baloian Co. v. Commissioner

68 T.C. 620 · United States Tax Court · Jul 27, 1977

Glendinning, McLeish & Co. v. Commissioner, 24 B.T.A. 518 (1931); Patchen v. Commissioner, 27 T.C. 592 (1956); Hearn v. … Va., Inc. v.

De Jong v. Commissioner

36 T.C. 896 · United States Tax Court · Aug 29, 1961

DeJong, Petitioners, v. Commissioner of Internal Revenue, Respondent De Jong v. Commissioner Docket No. 86903 United States Tax Court 36 T.C. 896 ; 1961 U.S. Tax Ct. … Wardwell , 35 T.C. 443 ; Bogardus v. Commissioner , 302 U.S. 34 , 41 ; *96 Commissioner v. Duberstein , 363 U.S. 278 .