Case law

Montgomery Bldg. Realty Co. v. Commissioner

7 T.C. 417 · United States Tax Court · Jul 30, 1946

Coleman look into the possibility of a general re-finance plan and report back to the Board of Directors as soon as possible." … Helvering v. Alabama Asphaltic Limestone Co ., 315 U.S. 179 ; Palm Springs Holding Corporation v. Commissioner , 315 U.S. 185 . Here, unlike the transfer in Helvering v.

MoneyGram International, Inc. v. Commissioner

144 T.C. 1 · United States Tax Court · Jan 7, 2015

Magruder v. … Meyer v. Am. Comty.

Mathews v. Commissioner

61 T.C. 12 · United States Tax Court · Oct 3, 1973

Van Zandt v. Commissioner, 341 F. 2d 440 (C.A. 5, 1965), affirming 40 T.C. 824 (1963), certiorari denied 382 U.S. 814 (1965); Brown v. Commissioner, 180 F. 2d 926 (C. … See Brown v. Commissioner, supra; Alden B. Oakes, supra; Albert T. Felix, 21 T.C. 794 (1954).

GPD, Inc. v. Commissioner

60 T.C. 480 · United States Tax Court · Jun 26, 1973

The Board of Tax Appeals held that, although the transferor’s cost was proper in computing taxable income, it was the book cost for the corporation that should be used in computing earnings and profits for the purposes of … In short, I find the reasoning of Judge Battisti in Ostendorf-Morris Co. v. United States, an unreported case (N.D. Ohio 1968, 26 A.F.T.R. 2d 70 -5369, 70-2 U.S.T.C. par. 9550), totally persuasive.

Horn v. Commissioner

4 T.C.M. 1093 · United States Tax Court · Dec 12, 1945

Horn v. Commissioner. Horn v. Commissioner Docket No. 4934. United States Tax Court 1945 Tax Ct. Memo LEXIS 18 ; 4 T.C.M. (CCH) 1093 ; T.C.M. (RIA) 45367 ; December 12, 1945 *18 E. B. Graham, Esq., Citizens Nat. … Brown, Winifred M. Brown, and M. M. Brown "All of 23 South Center Street, Springfield, O." The return *20 showed a total income of $199,654.64 of which $142,972.16 was slot machine proceeds.

Anderson v. Commissioner

5 T.C. 1317 · United States Tax Court · Dec 27, 1945

Much the same argument as that advanced by petitioner has been answered adversely to him in Hubbell v. Commissioner, 150 Fed. (2d) 516, affirming 3 T. C. 626 . … Although not voting on the particular orders and resolutions, petitioner was present at every meeting of the boards of directors at which any action with respect to the trusts was taken.

Krueger v. Commissioner

48 T.C. 824 · United States Tax Court · Sep 14, 1967

Cromwell v. County of Sac, supra, 353 . And see Russell v. Place, 94 U.S. 606 ; Southern Pacific R. Co. v. United States, 168 U.S. 1, 48 ; Mercoid Coryp v Mid-Continent Co., 320 U.S. 661, 671 . … In Sanborn v.

Elrod v. Commissioner

87 T.C. 1046 · United States Tax Court · Nov 12, 1986

[Koch v. … Petitioner mistakenly relies upon Scheffres v. Commissioner, T.C. Memo. 1969-41 , in which the taxpayers were entitled to a charitable contribution deduction for their transfer of land to the county board of education.

Estate of Doane v. Commissioner

10 T.C. 1258 · United States Tax Court · Jun 30, 1948

For his disallowance respondent relies upon language in Cerf v. Commissioner (C. C. A., 3d Cir.), 141 Fed. (2d) 564, affirming 1 T. C. 1087 . … But see Brown v. Routzahn (C. C. A., 6th Cir.), 63 Fed. (2d) 914, 916; certiorari denied, 290 U. S. 641 : “» « « me decedent was in possession of the estate from 1912 until it was transferred to the trustees in 1920.

Borall Corp. v. Commissioner

5 T.C.M. 933 · United States Tax Court · Oct 30, 1946

Davidson v. Commissioner, 305 U.S. 44 ; Curtis v. Commissioner, 89 Fed. (2d) 736 . … In Louisville Trust Co. v. Glenn, 65 Fed.

Cronstroms Mfg., Inc. v. Commissioner

36 T.C. 500 · United States Tax Court · Jun 9, 1961

Cronstroms Manufacturing, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent. Cronstroms, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Cronstroms Mfg., Inc. v. … was thereafter presented and adopted at a special meeting of the board of directors on January 11, 1954.

Venture Funding v. Commissioner

110 T.C. 236 · United States Tax Court · Mar 26, 1998

Brown v. Gardner, 513 U.S. 115, 117 (1994) (citing King v. St. Vincent’s Hosp., 502 U.S. 215, 221 (1991) (“[T]he meaning of statutory language, plain or not, depends on context.”)). … In Chevron, U.S.A., Inc. v.

Ripy Bros. Distillers, Inc. v. Commissioner

11 T.C. 326 · United States Tax Court · Sep 22, 1948

In support of its position it relies on Commissioner v. Falcon Co . (CCA-5), 127 Fed. (2d) 277 ; Novo Trading Corporation v. Commissioner (CCA-2), 113 Fed. (2d) 320 ; Howell Turpentine Co. v. … The respondent relies on such cases as Commissioner v. Court Holding Co ., 324 U.S. 331 ; United States v. Phellis , 257 U.S. 156 ; MacQueen Co. v. Commissioner (CCA-3), 67 Fed. (2d) 857 ; Meurer Steel Barrel Co. v.

Duell v. Commissioner

19 T.C.M. 1381 · United States Tax Court · Nov 23, 1960

Duell v. Commissioner. Duell v. Commissioner Docket No. 78696. United States Tax Court T.C. Memo 1960-248 ; 1960 Tax Ct. Memo LEXIS 42 ; 19 T.C.M. (CCH) 1381 ; T.C.M. … Commissioner v. Burdick, 59 Fed. (2d) 395 , affirming 20 B.T.A. 742 ; Julius C. Miller, 45 B.T.A. 292 ; Peabody Coal Co. v. United States, 8 Fed. Supp. 845 .

Standard Television Tube Corp. v. Commissioner

64 T.C. 238 · United States Tax Court · May 19, 1975

Schlude v. Commissioner, 372 U.S. 128 (1963); American Automobile Assn. v. United States, 367 U.S. 687 (1961); Automobile Club of New York, Inc. v. … Brown v. Helvering, 291 U.S. 193, 201-202 . And this is so regardless of whether its obligation is direct or otherwise. [45 T.C. at 166.]

Mathis v. Commissioner

57 T.C.M. 519 · United States Tax Court · May 24, 1989

Brown, for the petitioners. Meryl J. Fuchs-Goldberg , *255 for the respondent. … The petition was *258 approved by the Fulton County Board of Commissioners on June 6, 1979.

Green v. Commissioner

12 T.C. 656 · United States Tax Court · Apr 29, 1949

OppeR, Judge: We can not distinguish this proceeding in any particular from Ney v. United States (Dist. Ct., Ark.), 77 Fed. Supp. 1005; affd. (C. C. A., 8th Cir.), 171 Fed. (2d) 449. … Whether a further amount would have been allowed for board and lodging for the few days spent at the taxpayer’s original “home,” had they been claimed and proved, can not be ascertained from the record in that case, but consideration

Seventeen Seventy St. v. Comm'r

107 T.C.M. 1599 · United States Tax Court · Jun 19, 2014

V. View Plane Variance On January 6, 2003, Seventeen Seventy submitted a view plane variance request to the Planning Board. … See, e.g., United States v.

Farber v. Commissioner

57 T.C. 714 · United States Tax Court · Mar 6, 1972

One week later the petitioner’s lawn began “turning yellowish,” and about 2 weeks thereafter the lawn had turned completely brown and died. … Helvering v. Owens, 305 U.S. 468, 471 (1939). There is nothing in the statute or regulations that limits the deduction of the amount of the loss actually sustained to the amount of the insurance recovery.

Orange & Rockland Utilities, Inc. v. Commissioner

86 T.C. 199 · United States Tax Court · Feb 18, 1986

Bay State Gas Co. v. … In Decision, Inc. v.