Case law

Heckett Eng'g Inc. v. Commissioner

6 T.C.M. 1305 · United States Tax Court · Dec 23, 1947

Lane & Bodley Co. v. … Lucas v. Ox Fibre Brush Co., 281 U.S. 115 ↩ . 2.

McDonald v. Commissioner

1 T.C. 738 · United States Tax Court · Mar 10, 1943

McDonald, Petitioner, v. Commissioner of Internal Revenue, Respondent McDonald v. Commissioner Docket No. 109104 United States Tax Court 1 T.C. 738 ; 1943 U.S. Tax Ct. … The petitioner is an individual residing at 6 Brown Street, Ashley, Pennsylvania.

McEwen v. Commissioner

6 T.C. 1018 · United States Tax Court · May 9, 1946

In Commissioner v. Smith, 324 U. … See Old Colony Trust Co. v. Commissioner, 279 U.

Ellison v. Commissioner

55 T.C. 142 · United States Tax Court · Oct 27, 1970

Singer Manufacturing Co. v. Rahn, 132 U.S. 518, 523 (1889); National Labor Relations Board v. Phoenix Mut. L. Ins. … National Labor Relations Board v. Phoenix Mut. L. Ins. Co., supra at 986. The parties agree as to the legal standard to be used in this case.

Trebilcock v. Commissioner

64 T.C. 852 · United States Tax Court · Aug 7, 1975

Lilly v. Commissioner, 343 U.S. 90, 93 (1952). “Ordinary has the connotation of normal, usual, or customary.” Deputy v. du Pont, 308 U.S. 488, 495 (1940). … We thus apply the rule in Cohan v.

Grahm v. Commissioner

26 T.C. 315 · United States Tax Court · May 23, 1956

As was said in Magruder v. … The abstract of the list was filed, with the town clerk on January 28, 1949, and the tax rate was set by the Board of Apportionment and Taxation on February 22, 1949.

Estate of Zaiger v. Commissioner

64 T.C. 927 · United States Tax Court · Aug 25, 1975

Lappin, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent; Beatrice Zaiger, Petitioner v. Commissioner of Internal Revenue, Respondent Estate of Zaiger v. … Brown , for the petitioners. Barry J. Laterman , for the respondent. Goffe , Judge .

Century Data Systems, Inc. v. Commissioner

80 T.C. 529 · United States Tax Court · Mar 8, 1983

Commissioner, 32 B.T.A. 66 (1935); Elgin Compress Co. v. Commissioner, 31 B.T.A. 273 (1934) (reviewed by the Board); Brooklyn City Railroad Co. v. … The Board held that respondent had no authority to compute the taxpayer’s liability on any basis other than the same fiscal year for which the taxpayer actually kept its books.

Southwest Natural Gas Co. v. Commissioner

14 T.C. 81 · United States Tax Court · Jan 27, 1950

At meetings held on December 5, 1940, the board of directors of petitioner and the board of directors of Peoples, respectively, unanimously adopted a resolution approving and authorizing the execution of a proposed agreement … of directors was substantially an amalgamation of the prior boards of directors of petitioner and Peoples.

Horne v. Commissioner

59 T.C. 319 · United States Tax Court · Nov 27, 1972

He held that office until 1955, when he was elevated to president and chairman of the board — positions which he held through 1960. Petitioner and Naisbitt were also members of the board of both CORP and CO. … Compare United States v. Hoffman, 423 F. 2d 1217 (C.A. 9, 1970), and Jones v. Bacon, 40 N.E. 216 N.Y. (Ct. App. 1895), supra, with Howell v.

Lidgerwood Manufacturing Co. v. Commissioner

22 T.C. 1152 · United States Tax Court · Aug 31, 1954

Commissioner v. Auto Strop Safety Razor Co., 74 F. 2d 226 (C. A. 2, 1934); Johnson, Drake & Piper v. Helvering, 69 F. 2d 151 (C. A. 8, 1934), certiorari denied 292 U. S. 650 (1934), affirming 27 B. T. … A. 585 (1933); United States v. Oregon-Washington R. & Nav. Co., 251 F. 211 (C. A. 2, 1918) ; Estate of L. W. Mallory, 27 B. T. A. 750 (1933); Franklin Q. Brown, et al., 9 B. T. A. 965 (1927).

Breyer v. Commissioner

3 T.C.M. 48 · United States Tax Court · Jan 20, 1944

Breyer, Jr. v. Commissioner. Edith S. Breyer v. Commissioner. Catharine Breyer Van Bomel v. Commissioner. Breyer v. Commissioner Docket Nos. 111808, 111835, 111837. United States Tax Court 1944 Tax Ct. … The Brown case involved gift taxes. See also Ralph J. Green, 3 T.C. 74 .

Producers Crop Improv. Asso. v. Commissioner

7 T.C. 562 · United States Tax Court · Aug 16, 1946

Producers Crop Improvement Association, Petitioner, v. Commissioner of Internal Revenue, Respondent Producers Crop Improv. Asso. v. Commissioner Docket Nos. 6404, 9544 United States Tax Court 7 T.C. 562 ; 1946 U.S. … The bylaws of the petitioner authorized the board of directors to set aside reasonable and adequate reserves before paying dividends on the preferred or patronage dividends to common stockholders.

Estate of Durkin v. Commissioner

99 T.C. 561 · United States Tax Court · Nov 18, 1992

By July 15, 1974, Green was chairman of the board. James C.B. Millard, Jr. (Millard), Green’s attorney, was executive vice president. James J. … Petitioners, Green, and Millard were the members of the board of directors of Blue Coal who authorized the resolution. c.

Wellman Operating Corp. v. Commissioner

33 T.C. 162 · United States Tax Court · Oct 30, 1959

Wellman Operating Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Wellman Operating Corp. v. Commissioner Docket No. 63326 United States Tax Court 33 T.C. 162 ; 1959 U.S. Tax Ct. … KOMA, Inc. v. *188 , 189 F. 2d 390 (C.A. 10), affirming a Memorandum Opinion of this Court.

Hubbell v. Commissioner

3 T.C. 626 · United States Tax Court · Apr 17, 1944

Hubbell, Petitioner, v. Commissioner of Internal Revenue, Respondent. Elias F. Wildermuth, Petitioner, v. Commissioner of Internal Revenue, Respondent Hubbell v. … On December 5, 1940, the board of directors of the Optical Co. passed a resolution to the effect that the annuity contracts should be reinstated and the current payments paid.

Buse v. Commissioner

71 T.C. 1129 · United States Tax Court · Mar 29, 1979

V. Morton. … Cascade Lumber Co. v. Squire, an unreported case (W.D.

Lo Bue v. Commissioner

22 T.C. 440 · United States Tax Court · May 28, 1954

LoBue, Petitioner, v. Commissioner of Internal Revenue, Respondent Lo Bue v. Commissioner Docket No. 41595 United States Tax Court 22 T.C. 440 ; 1954 U.S. Tax Ct. … In 1946 he became president, and in 1949 chairman of the board. From 1944 through 1947, he was the company's chief executive officer.

Masterson v. Commissioner

1 T.C. 315 · United States Tax Court · Dec 22, 1942

The proceedings in that case were tendered to the Court of Appeals upon its review of the Board’s decision. … Jeter v. Hewitt, 22 How. (U. S.) 352, 364.

Shiffman v. Commissioner

32 T.C. 1073 · United States Tax Court · Aug 17, 1959

Corp. v. United States, (Ct. Cl. 1956) 142 F. Supp. 899 . The instant facts present even a stronger case for exemption under section 101(6) than the facts under Ohio Furnace Co. … See Cummins-Collins Foundation, 15 T.C. 613 ; Samuel Friedland Foundation v. United States, (D.N.J. 1956) 144 F. Supp. 74 .