Case law

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  • Facebook, Inc. & Subsidiaries

    United States Tax Court · May 22, 2025

    (v)(E). … Co. v.

    Cited 0 timesPublished
  • 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

    Cited 0 timesPublished
  • Munter v. Commissioner

    5 T.C. 108 · United States Tax Court · May 22, 1945

    v. … Helvering, 79 Fed. (2d) 12 ; Murchison Estate v. Commissioner, 76 Fed. (2d) 641; United States v. Kauffmann, 62 Fed. (2d) 1045 ; Barnes v. United States, 22 Fed. Supp. 282; Helen V. Crocker, supra. See Commissioner v.

    Reversed by Commissioner v. Munter, 331 U.S. 210 (1947)Cited 5 timesPublished
  • Smith v. Commissioner

    75 T.C.M. 2155 · United States Tax Court · Apr 16, 1998

    See Schroeder v. … See Welch v. Helvering, 290 U.S. at 115.

    Cited 2 timesUnpublished
  • Wahlert v. Commissioner

    17 T.C. 655 · United States Tax Court · Oct 10, 1951

    V. Kisting, L. M. Schmitt, M. M. Kuehn, V. G. Kisting, and petitioner. … In Burnet v.

    Cited 1 timesPublished
  • 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.

    Cited 1 timesPublished
  • Nestle Holdings v. Commissioner

    70 T.C.M. 682 · United States Tax Court · Sep 14, 1995

    Brown (Brown), in which Brown stated: Although control premiums may be required to induce selling shareholders to pass control, other rationale is necessary in order for it to be a sound economic investment for the acquiror … The record here corroborates Brown's description of control premiums.

    Cited 23 timesUnpublished
  • Bell Electric Co. v. Commissioner

    45 T.C. 158 · United States Tax Court · Nov 19, 1965

    In American Automobile Association v. United States, 367 U.S. 687 , and Schlude v. … Brown v. Helvering, 291 U.S. 193, 201-202 . And this is so regardless of whether its obligation is direct or otherwise. Petitioners rely in part upon Bressner Radio, Inc. v.

    Cited 0 timesPublished
  • Conroy v. Commissioner

    41 T.C. 685 · United States Tax Court · Feb 26, 1964

    See Corkum v. United States, 204 F. Supp. 471 . … Brown, 25 T.C. 220 , are to some extent factually similar to the instant cases in that they considered tax problems of retired members of the Baltimore Police Department.

    Cited 14 timesPublished
  • Nevin v. Commissioner

    11 T.C. 59 · United States Tax Court · Jul 20, 1948

    A., Petitioner, v. Commissioner of Internal Revenue, Respondent Nevin v. Commissioner Docket No. 15218 United States Tax Court 11 T.C. 59 ; 1948 U.S. Tax Ct. … A. 268 , *137 and Dimock v. Corwin , 19 Fed. Supp. 56 .

    Cited 1 timesPublished
  • Burke v. Commissioner

    42 T.C. 1021 · United States Tax Court · Sep 9, 1964

    A special meeting of the board of directors of the Pueblo company was thereafter held on December 20, 1956. … Coady, supra, and with United States v. Marett, 325 F. 2d 28 (C.A. 5, 1963). Any further discussion of this issue is deemed unnecessary.

    Cited 7 timesPublished
  • Bilar Tool & Die Corp. v. Commissioner

    62 T.C. 213 · United States Tax Court · May 15, 1974

    We find nothing in the recent Supreme Court opinions in Woodward v. Commissioner, 397 U.S. 572 (1970), and United States v. … See Transamerica Corporation v. United States, 254 F. Supp. 504 (N.D. Cal. 1966).

    Cited 3 timesPublished
  • Goldwyn v. Commissioner

    9 T.C. 510 · United States Tax Court · Sep 30, 1947

    Samuel Goldwyn, Petitioner, v. Commissioner of Internal Revenue, Respondent Goldwyn v. Commissioner Docket No. 8770 United States Tax Court 9 T.C. 510 ; 1947 U.S. Tax Ct. … United States v. Guinzburg, *94 supra [ 278 Fed. 363 ]; Plant v. Walsh, supra [ 280 Fed. 722 ]; and Appeal of A. H. Stange, supra [1 B. T. A. 810].

    Cited 12 timesPublished
  • Stidger v. Commissioner

    40 T.C. 896 · United States Tax Court · Sep 3, 1963

    In Commissioner v. Flowers, 326 U.S. 465 , the U.S. … See Commissioner v. Flowers, 326 U.S. 465 , 66 S.Ct. 250 , 90 L. Ed. 203 ; Barnhill v. Commissioner, 4 Cir., 148 F. 2d 913 , 159 A.L.R. 1210 .

    Reversed by Howe A. Stidger and Betty M. Stidger v. Commissioner of Internal Revenue, 355 F.2d 294 (1965)Cited 8 timesPublished
  • Union Oil Co. v. Commissioner

    101 T.C. 130 · United States Tax Court · Jul 28, 1993

    Co. v. Commissioner, 634 F.2d 1029, 1042 (6th Cir. 1980), affg. 68 T.C. 39 (1977); Allstate Ins. Co. v. United States, 329 F.2d 346, 349 (7th Cir. 1964); First Chicago Corp. v. Commissioner, 96 T.C. 421, 439 (1991). … Co. v.

    Cited 5 timesPublished
  • Estate of Bartell v. Comm'r

    147 T.C. 140 · United States Tax Court · Aug 10, 2016

    As we noted in Biggs v. … Co. v.

    Cited 1 timesPublished
  • Carpenter v. Commissioner

    20 T.C. 603 · United States Tax Court · Jun 15, 1953

    Carpenter, Petitioner, v. Commissioner of Internal Revenue, Respondent Carpenter v. Commissioner Docket No. 30631 United States Tax Court 20 T.C. 603 ; 1953 U.S. Tax Ct. … This certificate is transferable only on the books of said association after the express consent of the Board of Directors of said association to such transfer has been first had and obtained. 4.

    Cited 14 timesPublished
  • Johns v. Commissioner

    53 T.C.M. 442 · United States Tax Court · Mar 26, 1987

    Helba v. Commissioner, 87 T.C. 983 (1986) ; Zirker v. Commissioner, 87 T.C. 970 (1986) . … In Hilton v.

    Cited 1 timesUnpublished
  • Bower v. Commissioner

    10 T.C. 37 · United States Tax Court · Jan 12, 1948

    As in George v. … In Brown v.

    Cited 0 timesPublished
  • Smith v. Commissioner

    60 T.C. 279 · United States Tax Court · May 23, 1973

    The president of GMI reports both to the board of regents of GMI and to the vice president for personnel administration of GMC. … This provision of the regulations was upheld by the Supreme Court in Bingler v. Johnson, 394 U.S. 741 (1969).

    Cited 4 timesPublished

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