Case law

Kleberg v. Commissioner

2 T.C. 1024 · United States Tax Court · Nov 25, 1943

Lemar v. Garner, 121 Texas 502 ; 50 S.W. (2d) 769 ; Brown v. Humble Oil & Refining Co., 126 Texas 296 ; 83 S.W. (2d) 935 ; on rehearing, 87 S.W. (2d) 1069 ; Railroad Commission v. Oil Co., 310 U. S. 573, 579 . … See Colston v. Burnet, 59 Fed. (2d) 867; Small v. Commissioner, 27 B. T. A. 1219; Paul, Selected Studies in Federal Taxation, Second Series, p. 24 * * *. In Raybestos-Manhattan Co. v.

Burnetta v. Commissioner

68 T.C. 387 · United States Tax Court · Jun 13, 1977

Packard v. Commissioner, 63 T.C. 621, 629 (1975). Whether or not two parties stand in an employer-employee relationship is a factual question. Simpson v. Commissioner, 64 T.C. 974, 984 (1975); Ellison v. … Pollnow v. Commissioner, 35 T.C. 715 (1961); Liberty Machine Works, Inc. v. Commissioner, 62 T.C. 621 (1974); Comprehensive Designers International, Ltd. v. Commissioner, 66 T.C. 348 (1976).

Webb Export Corp. v. Commissioner

91 T.C. 131 · United States Tax Court · Jul 26, 1988

The following were representative costs: Felling $ 10/1,000 Board ft. (1"x12"x12") Skidding 20/1,000 Board ft. Bucking 5/1,000 Board ft. Loading 5-10/1,000 Board ft. Hauling 20-40/1,000 Board ft. … Although Dave Fischbein v.

John Kelley Co. v. Commissioner

1 T.C. 457 · United States Tax Court · Jan 15, 1943

John Kelley Company, Petitioner, v. Commissioner of Internal Revenue, Respondent John Kelley Co. v. Commissioner Docket No. 109088 United States Tax Court 1 T.C. 457 ; 1943 U.S. Tax Ct. … On January 11, 1937, a special meeting of the board of directors of the petitioner corporation was held and a plan of recapitalization was adopted.

SAMPSON v. COMMISSIONER

2005 T.C. Summary Opinion 30 · United States Tax Court · Mar 23, 2005

Summary Opinion 2005-30 UNITED STATES TAX COURT KEISHA SAMPSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2462-04S. … During the 2001-2002 school year, Destiny Sampson attended Brown Primary School (Brown) in Smithville, Texas.

Aspegren v. Commissioner

51 T.C. 945 · United States Tax Court · Mar 12, 1969

Authority to determine how many shares a person could buy was given by the boards of directors of the companies to Henry Bubb, chairman of the boards, and to Karl. … Later, however, in Commissioner v.

MacDonald v. Commissioner

5 T.C.M. 516 · United States Tax Court · Jun 25, 1946

MacDonald v. Commissioner. Ruth B. Peyton v. Commissioner. MacDonald v. Commissioner Docket Nos. 6245, 6810. United States Tax Court 1946 Tax Ct. Memo LEXIS 156 ; 5 T.C.M. (CCH) 516 ; T.C.M. … Brown as secretary. B. B. Brown personally delivered the certificate to Jean B. Fitzgerald.

Duffy v. Commissioner

2 T.C. 568 · United States Tax Court · Aug 13, 1943

McDonald v. Williams, 174 U. S. 397 ; Quintal v. Adler. 146 Misc. 300 ; 262 N. Y. Supp. 126 ; affd.. 239 App. Div. 775 ; 263 N. Y. Supp. 943 ; aff'd., 264 N. Y. 452 ; 191 N. E. 509 . … See Cox v. Leahy. 209 App. Div. 313 ; 204 N. Y. Supp. 741 .

Kenna Trading, LLC v. Comm'r

143 T.C. 322 · United States Tax Court · Oct 16, 2014

The one exception is Christopher Heath Brown, an investor who questioned Mr. Rogers as to when he would see results. Mr. Rogers essentially-rebuffed Dr. Brown, saying that he should be happy with the tax losses, and Dr. … Brown did not complain again.

Insilco Corp. v. Commissioner

73 T.C. 589 · United States Tax Court · Dec 26, 1979

Breech v. … Shearer v.

Swenson v. Commissioner

37 T.C. 124 · United States Tax Court · Oct 31, 1961

McFeely v. Commissioner, 296 U.S. 102 (1935); Helvering v. San Joaquin Co., 297 U.S. 496 (1936). … Pope v. Landry, 39 Del. 437 , 1 A. 2d 589 (1938). In Colvocoresses v. W. S.

Durbin Paper Stock Co. v. Commissioner

80 T.C. 252 · United States Tax Court · Jan 20, 1983

Koshland v. Helvering, 298 U.S. 441, 447 (1936); Arrow Fastener Co. v. … See, e.g., Estate of Boeshore v.

C. R. Lindback Foundation v. Commissioner

4 T.C. 652 · United States Tax Court · Jan 31, 1945

We do not think that the amount of discretion vested in the board of managers of the Foundation by its bylaws or the amount of discretion actually exercised by the board requires us to make a holding here contrary to our … The holding of the court in Dayton Bronze Bearing Co. v.

Watson v. Commissioner

31 T.C. 1014 · United States Tax Court · Feb 18, 1959

Watson and Betty Jane Watson, Petitioners, v. Commissioner of Internal Revenue, Respondent Watson v. Commissioner Docket No. 65185 United States Tax Court 31 T.C. 1014 ; 1959 U.S. Tax Ct. … Brown, Jr., Esq ., for the respondent. Tietjens , Judge . Murdock, Turner, Opper , and Mulroney, JJ ., dissent.

Weinert v. Commissioner

31 T.C. 918 · United States Tax Court · Jan 30, 1959

Commissioner v. P. G. Lake, Inc., 356 U.S. 260 , rehearing denied 356 U.S. 964 . … Anderson v. Helvering, 310 U.S. 404 ; Helvering v. Horst, 311 U.S. 112 ; Commissioner v. Slagter, 238 F. 2d 901 (C.A. 7, 1956), reversing 24 T.C. 935 . The facts in this case distinguish it from Carl A.

Estate of Kinney v. Commissioner

39 T.C. 728 · United States Tax Court · Jan 31, 1963

Petitioner cites Brown v. Routzahn, 63 F. 2d 914 (C.A. 6, 1933), in which decedent had renounced property given to him under the will of his wife who predeceased him. … Helvering v. Schaupp, 71 F. 2d 736 (C.A. 8, 1934); Smith v. United States, 265 F. 2d 834 (C.A. 5, 1959).

Fisher v. Commissioner

16 T.C. 1144 · United States Tax Court · May 23, 1951

Fisher, Petitioner, v. Commissioner of Internal Revenue, Respondent Fisher v. Commissioner Docket No. 29962 United States Tax Court 16 T.C. 1144 ; 1951 U.S. Tax Ct. … He worked at Schenectady during 1947 and, while there, paid about $ 25 to $ 30 a week for room and board. He was unmarried. *1145 His brother, Louis, was married *185 and lived in Warrensburg, New York.

Baker Commodities, Inc. v. Commissioner

48 T.C. 374 · United States Tax Court · Jun 23, 1967

Since June of 1961, all 10 stockholders of New Baker have served on its board of directors and have attended and voted at the board meetings. … Malat v. Riddell, 383 U.S. 569 (1966).

Estate of Sweeney v. Commissioner

39 T.C.M. 201 · United States Tax Court · Sep 19, 1979

In Commissioner v. … In Unser v.

Medical Weight Control Specialist v. Comm'r

109 T.C.M. 1243 · United States Tax Court · Mar 18, 2015

On May 12 and 21, 2014, respectively, the California Franchise Tax Board issued to petitioner a certificate of revivor and a certificate of relief from contract voidability. … See Brown v. Commissioner, 78 T.C. 215, 218 (1982). Unlike a traditional statute of limitations, the 90-day period of section 6213(a) generally cannot be tolled or extended. See Rich v.