Case law

Howze v. Commissioner

2 T.C. 1254 · United States Tax Court · Dec 30, 1943

S. 399 , and many Board and court cases which have followed that case. The petitioner points out in her brief that United States v. … In Welch v.

Dressler v. Commissioner

56 T.C. 210 · United States Tax Court · May 6, 1971

John Dressler and Charlotte Dressler, Petitioners, v. Commissioner of Internal Revenue, Respondent Dressler v. Commissioner Docket No. 104-71S United States Tax Court 56 T.C. 210 ; 1971 U.S. Tax Ct. … as a minister and performed no functions of a sacerdotal character was not a "minister of the gospel" within the meaning of section 107 even though 9 of the 11 professional employees of the Board of Christian Social Concerns

Murphy v. Commissioner

45 T.C.M. 621 · United States Tax Court · Feb 1, 1983

Murphy that the questions asked about the Church and its operations are privileged and inviolate and cannot be answered except byt [sic] the Board of Directors of the Universal Life Church, Inc., in Modesto, California." … See also Kellman v. Commissioner, T.C. Memo. 1981-615 ; Brown v. Commissioner, T.C. Memo. 1980-553 ; United States v. Toy National Bank, an unreported case ( N.D.

Nirosta Corp. v. Commissioner

8 T.C. 987 · United States Tax Court · May 9, 1947

In May 1943 the officers of the corporation were as follows: Chairman of the board-Howland H. Sargeant President-Allen A. Dicke Vice president-Hellmer R. Johnson Secretary-Edgar M. Cullman Treasurer-Paul S. … A. 498; Noteman v. Welch, 108 Fed. (2d) 206. In the case at bar the taxpayer had the benefit of a ruling by the revenue agent in 1940 that it was a holding company.

Moorer v. Commissioner

12 T.C. 270 · United States Tax Court · Feb 28, 1949

Moorer, Petitioner, v. Commissioner of Internal Revenue, Respondent Moorer v. Commissioner Docket No. 16272 United States Tax Court 12 T.C. 270 ; 1949 U.S. Tax Ct. … The respondent relies primarily upon Leland v. Commissioner , 50 Fed. (2d) 523 , and Rheinstrom v. Connor , 125 Fed. (2d) 790 .

Dowd v. Commissioner

37 T.C. 399 · United States Tax Court · Dec 4, 1961

Dowd, Petitioners, v. Commissioner of Internal Revenue, Respondent Dowd v. Commissioner Docket No. 84485 United States Tax Court 37 T.C. 399 ; 1961 U.S. Tax Ct. … His resignation was accepted by the board of regents of the university on March 3, 1956, effective June 15, 1956.

C. P. A. Co. v. Commissioner

7 T.C. 912 · United States Tax Court · Oct 2, 1946

The petitioner relies upon Massachusetts Protective Association, Inc. v. United States, 114 Fed. (2d) 304. … Equitable Life Assurance Society v. Commissioner, 1935, 33 B. T.

Californians Helping to Alleviate Med. Problems, Inc. v. Comm'r

128 T.C. 173 · United States Tax Court · May 15, 2007

As stated by the Board of Tax Appeals in Alverson v. Commissioner, 35 B.T.A. 482, 488 (1937): “The statute is not so restricted as to confine deductions to a single business or principal business of the taxpayer. … See Peyton v. Commissioner, T.C. Memo. 2003-146 ; Franklin v. Commissioner, T.C. Memo. 1993-184 ; Vasta v. Commissioner, T.C. Memo. 1989-531 ; see also S. Rept. 97-494 (Vol. 1), at 309 (1982).

Dade-Commonwealth Title Co. v. Commissioner

6 T.C. 332 · United States Tax Court · Mar 5, 1946

In Lawrence v. McCalmont, 2 How. 425 , Mr. … The Board of Tax Appeals had held that the evidence adduced failed to show that the bonds were issued for consideration or that the taxpayer was legally bound to pay interest on them. Cf. Commissioner v. Park (C. C.

Kuper v. Commissioner

61 T.C. 624 · United States Tax Court · Feb 4, 1974

See Griffiths v. Commissioner, 308 U.S. 355, 358 (1939); Minnesota Tea Co. v. Helvering, 302 U.S. 609, 613 (1938). … Sammons v. Commissioner, supra at 452.]

Linwood Cemetery Asso. v. Commissioner

87 T.C. 1314 · United States Tax Court · Dec 17, 1986

Child v. United States, 540 F.2d 579, 582-584 (2d Cir. 1976), cert. denied 429 U.S. 1092 (1977); Gund’s Estate v. … How the board of directors and the officers are selected is not clear from the record. Petitioner carried the cemetery land on its books at its cost of $1.

Ransom v. Commissioner

2 T.C. 647 · United States Tax Court · Sep 8, 1943

While the line of distinction between Commissioner v. Bishop Trust Co., supra, and Weigel v. … Furthermore, we think, as argued by petitioner, that the instant case on its facts is ruled by Weigel v. Commissioner, rather than by Commissioner v. Bishop Trust Co.

Pomponio v. Commissioner

33 T.C. 1072 · United States Tax Court · Mar 31, 1960

Petitioner ivas secretary-treasurer, a member of the board of directors, and a stockholder in Donna Lee. … Petitioner was secretary-treasurer, a member of the board of directors, and a stockholder in Greenbrier.

Rhode Island Hospital Trust Co. v. Commissioner

7 T.C. 211 · United States Tax Court · Jun 24, 1946

See National Investors Corporation v. Hoey, 144 Fed. (2d) 466. Disregard of a corporate entity under Higgins v. Smith, supra, is dependent upon a finding that it is but a fiction or a sham. … It had its own board of directors abd officers, through whom it acted j it had its own books and records and was never subject to the, control of any officers or committees of petitioner, as such.

First State Bank v. Commissioner

8 T.C. 831 · United States Tax Court · Apr 17, 1947

On that date, at a regular monthly meeting of the board of directors, all directors (L. M. Price, A. E. Pronger, P. J. Pronger, U. N. … Thus, in Commissioner v.

Wiese v. Commissioner

70 T.C. 712 · United States Tax Court · Aug 17, 1978

Wiese, Petitioner v. Commissioner of Internal Revenue, Respondent Wiese v. Commissioner Docket No. 11614-77 United States Tax Court 70 T.C. 712 ; 1978 U.S. Tax Ct. … Brown , for the respondent. Wiles, Judge . WILES *712 OPINION This matter is before the Court on respondent's "Motion to Dismiss for Lack of Jurisdiction" filed December 22, 1977.

Farr v. Commissioner

11 T.C. 552 · United States Tax Court · Oct 7, 1948

See Commissioner v. Hopkinson, 126 Fed. (2d) 406, 411, and Ogle v. Helvering, 77 Fed. (2d) 338, 339. … New Colonial Ice Co. v. Helvering, 292 U. S. 435, 440 ; Hord v. Commissioner, 143 Fed. (2d) 73, 76; Davis v. Commissioner, 151 Fed. (2d) 441, 442.

Brannon's of Shawnee, Inc. v. Commissioner

71 T.C. 108 · United States Tax Court · Nov 6, 1978

See, e.g., Lubben v. Selective Service System Local Board, No. 27, 453 F. 2d 645 (1st Cir. 1972). As we have previously noted, lack of capacity has been dealt with by this Court only in a pre-final decision context. … Pierson, 415 F.2d 85 (10th Cir. 1969); Lawrence v. Williamson Ford, Inc., 13 Ill. App.3d 880 , 300 N.E.2d 636 (1973); Board of Education v. Herzog Bldg. Corp., 41 Ill. App.2d 44 , 190 N.E.2d 152 (1963); Sikes v.

Seasongood v. Commissioner

22 T.C. 671 · United States Tax Court · Jun 28, 1954

Murray Seasongood, Petitioner, v. Commissioner of Internal Revenue, Respondent. Agnes Seasongood, Petitioner, v. Commissioner of Internal Revenue, Respondent. Murray Seasongood and Agnes Seasongood, Petitioners, v. … Wrote letter to Board of Elections asking more rigid enforcement of election laws.

Huff v. Commissioner

135 T.C. 605 · United States Tax Court · Dec 22, 2010

HUFF, PETITIONER v. … Price, Ladd Christman Brown, Jr., and Justin L. Campolieta, for respondent.