Case law

Vietzke v. Commissioner

37 T.C. 504 · United States Tax Court · Dec 21, 1961

In Krietenstein v. Robinson, 126 Ind. … This language is at least as broad as that of Edwards v.

John Joseph Bauche

United States Tax Court · May 20, 2025

See Brown v. Commissioner, 158 T.C. 187, 192 (2022), aff’d, 116 F.4th 861 (9th Cir. 2024); see also Manko v. Commissioner, 126 T.C. 195, 199 (2006). … Brown v. Commissioner, T.C.

Manger Hotel Corp. v. Commissioner

10 T.C. 520 · United States Tax Court · Mar 24, 1948

Manger Hotel Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Manger Hotel Corp. v. Commissioner Docket No. 12882 United States Tax Court 10 T.C. 520 ; 1948 U.S. Tax Ct. … Brown & Sons Lumber Co ., 26 B. T. A. 1192 .

Betz v. Commissioner

90 T.C. 816 · United States Tax Court · Apr 26, 1988

Rule 25(c); Vermouth v. Commissioner, 88 T.C. 1488, 1491-1492 (1987); Ballantine v. Commissioner, 74 T.C. 516, 520 (1980); Dixon v. Commissioner, 60 T.C. 802, 804 (1973); Rea v. … Brown, Esq., of the firm of John T. Spoila & Associates, upon whom a copy of the answer was allegedly served. Respondent did not present any direct evidence that, in fact, the answer was mailed to the Court.

Stephenson Trust v. Commissioner

81 T.C. 283 · United States Tax Court · Sep 12, 1983

Koshland v. Helvering, 298 U.S. 441, 447 (1936); Arrow Fastener Co. v. … See also Commissioner v. Brown, 380 U.S. 563, 578-580 (1965). We do not intend to imply that we believe congressional inaction here means complete sanction of tax avoidance through multiple accumulation trusts.

Geo. J. Haenn, Inc. v. Commissioner

3 T.C. 1163 · United States Tax Court · Jul 31, 1944

Kornhauser v. United States, supra. Vet the transaction which gives rise to it must be of common or frequent occurrence in the type of business involved. Welch v. Helvering, supra, * * *. … The agreement provided for a permanent charge on the profits of the business ahead of dividends to the other stockholders and the court held, reversing the Board at 13 B. T.

Higgins v. Commissioner

16 T.C. 140 · United States Tax Court · Jan 19, 1951

Gasner v. Pierce et al., 286 Pa. 529 . … Corliss v. Bowers. 281 U. S. 376 . So far as reliance is placed on G. C.

Finney v. Commissioner

27 T.C.M. 1510 · United States Tax Court · Dec 5, 1968

Board Fence During 1960 petitioners constructed a board fence at a cost of $374 to serve as a paddock for the horses. … The Court of Appeals in Williams v.

Stow Mfg. Co. v. Commissioner

14 T.C. 1440 · United States Tax Court · Jun 30, 1950

Stow Manufacturing Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Stow Mfg. Co. v. Commissioner Docket No. 19923 United States Tax Court 14 T.C. 1440 ; 1950 U.S. Tax Ct. … The board then approved the agreement without change and authorized its execution.

Merrill v. Commissioner

9 T.C. 291 · United States Tax Court · Sep 9, 1947

In Williams v. … Stilgenbaur v. United States, 115 Fed. (2d) 283; Commissioner v. Shapiro, 125 Fed. (2d) 532. We too accepted the doctrine in McClellan v.

Columbia, N. & L. R. Co. v. Commissioner

14 T.C. 154 · United States Tax Court · Jan 31, 1950

Columbia, Newberry & Laurens Railroad Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Columbia, N. & L. R. Co. v. Commissioner Docket No. 20634 United States Tax Court 14 T.C. 154 ; 1950 U.S. … , how much, if any, income has been earned applicable to interest on this certificate; and any *289 part or the whole of any semi-annual interest not ordered by the Board of Directors to be paid, shall not thereafter be a

Sweets Co. of America, Inc. v. Commissioner

8 T.C. 1104 · United States Tax Court · May 20, 1947

Helvering v. Northwest Steel Rolling Mills, 311 U. S. 46 ; Crane-Johnson Co. v. Helvering, 311 U. S. 54 . The amount of tax which petitioner paid in fact reduced its invested capital. … United States v. Ogilvie Hardware Co., 330 U. S. 709 .

C. Blake McDowell, Inc. v. Commissioner

71 T.C. 71 · United States Tax Court · Oct 24, 1978

See also Bradley v. Richmond School Board, 416 U.S. 696, 710-716 (1974); Linkletter v. Walker, 381 U.S. 618, 625-627 (1965). Very recently, in Gulf Inland Corp. v. … Simpson v.

Fed. Labs. v. Comm'r

8 T.C. 1150 · United States Tax Court · May 29, 1947

Nicholson Pavement Co. v. Jenkins, 14 Wall. 422 . … As was said in Hatfield v.

Knobler v. Commissioner

59 T.C. 261 · United States Tax Court · Nov 20, 1972

Heilbron v. Heilbron, 158 Pa. 297 , 27 Atl. 967, 968 (1893). … Commissioner v. Lester, 366 U.S. 299 (1961).

Arata v. Commissioner

31 T.C. 346 · United States Tax Court · Nov 12, 1958

New Colonial Co. v. Helvering, 292 U. S. 435 ; Deputy v. DuPont, supra. … Ewing v. Commissioner, supra.

Ryan Constr. Corp. v. Commissioner

30 T.C. 346 · United States Tax Court · May 23, 1958

Ryan Construction Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent. Feigel Construction Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Ryan Constr. Corp. v. … Rather, they were a consequence of Roy's death and of the decision of petitioners' boards of directors to pay to Carrie a gratuity, as a memorial to Roy.

Estate of Campbell v. Commissioner

56 T.C. 1 · United States Tax Court · Apr 6, 1971

The first meeting of the board of directors of The Oaks was also held on August 1, 1962. … Sargent v. Whitfield & Co ., 226 Ky. 754 , 760 , 11 S. W. 2d 926 , 929 ; and Charles v. Hopkins , 217 Ky. 842 , 845 , 290 S. W. 720 , 721 ↩ . 7.

Scioto Provision Co. v. Commissioner

9 T.C. 439 · United States Tax Court · Sep 25, 1947

See Great Northern Railway Co. v. Commissioner, 40 Fed. (2d) 372; Burroughs Bldg. Material Co. v. Commissioner, 47 Fed. (2d) 178; Standard Oil Co. v. Commissioner, 129 Fed, (2d) 363; and Helvering v. … See Brown v. Cummins Distilleries Corporation, 56 Fed. Supp. 941; Bowles v. Beatrice Creamery Co., 56 Fed. Supp. 805 (reversed without discussion of the question under consideration, 146 Fed. (2d) 774); Bowles v.

National Lead Co. v. Commissioner

40 T.C. 282 · United States Tax Court · May 14, 1963

On the same day the petitioner’s board of directors authorized such sale. … Wickwire v.