Case law

Holt v. Commissioner

13 T.C.M. 979 · United States Tax Court · Oct 19, 1954

Holt v. Commissioner. Holt v. Commissioner Docket No. 44186. United States Tax Court T.C. Memo 1954-178 ; 1954 Tax Ct. Memo LEXIS 66 ; 13 T.C.M. (CCH) 979 ; T.C.M. … On October 13, 1947, petitioner signed a *68 contract with the Brown-Pacific-Maxon Company under which he continued to work in Guam as a welder for that company.

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).

Condor Int'l v. Commissioner

98 T.C. 203 · United States Tax Court · Feb 26, 1992

The certificate of incorporation requires all meetings of the board of directors to be held in the USVI. … Rowe revised minutes of the board meeting and directed her to substitute the new minutes in Condor's minute book.

Estate of Ingraham v. Commissioner

8 T.C. 701 · United States Tax Court · Mar 31, 1947

Ingraham, Deceased, Guaranty Trust Company of New York, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent Estate of Ingraham v. … Board of Foreign Missions of the Methodist Episcopal Church for use and benefit of Frances Taft Ingraham Hospital of Tsownsien, Shantung, China, or for its own purposes (1/2 part).

Garrett v. Commissioner

39 T.C. 316 · United States Tax Court · Nov 2, 1962

Thompson, 22 T.C. 507, 514 (1954), we quoted with approval from American Cigar Co. v. … The Board has found as a fact that petitioner made the advances fully believing that the obligations they created were worthless and uncollectible, and there is evidence to support such a finding. * * * Such advances, made

Estate of O'Brien v. Commissioner

57 T.C. 27 · United States Tax Court · Oct 5, 1971

American Crystal Sugar Co. v. Nicholas, 124 F. 2d 477 (C.A. 10, 1941). To this we add what the Court of Appeals said in Landa v. … [Scofield, Collector of Internal Revenue v. Greer, 185 F.2d 551, 552 (C.A. 5, 1950).] See S. E. Brown, 52 T.C. 50, 59-60 (1969); Sarah Helen Harrison, 17 T.C. 1350, 1357 (1952).

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.

Blanton v. Commissioner

46 T.C. 527 · United States Tax Court · Jul 28, 1966

Blanton and Fannie Blanton, Petitioners, v. Commissioner of Internal Revenue, Respondent Blanton v. Commissioner Docket No. 5840-64 United States Tax Court 46 T.C. 527 ; 1966 U.S. Tax Ct. … United States v. Simon , 281 F. 2d 520 (C.A. 6, 1960); Joseph P.

Markham v. Commissioner

62 T.C.M. 645 · United States Tax Court · Sep 3, 1991

In 1984, she became an equal partner with Woodrow Wilson Brown (Brown) *481 in a drug sales business that they operated out of Tucson, Arizona. … Estate of Ruben v. Commissioner , 33 T.C. 1071 (1960) .

Gold Kist v. Commissioner

104 T.C. 696 · United States Tax Court · Jun 26, 1995

Bank v. Commissioner and United States v. … Park v.

Estate of Bankhead v. Commissioner

60 T.C. 535 · United States Tax Court · Jul 9, 1973

Smyth v. Bameson, 181 F. 2d 143 (C.A. 9,1950). … Brown v. First National Bank of Montgomery, 261 Ala. 565 (1954).

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 .

Tanner v. Commissioner

64 T.C. 415 · United States Tax Court · Jun 12, 1975

See also John V. Prather, 50 T.C. 445 (1968). See Jamy Corp. v. Riddell, 337 F.2d 11 (9th Cir. 1964). … But see Jamy Corp. v. Riddell, 337 F.2d 11 (9th Cir. 1964). Pub. L. 91-467 (Oct. 19,1970), 84 Stat. 990 .

Alling v. Commissioner

102 T.C. 323 · United States Tax Court · Feb 24, 1994

Commissioner, supra note 9, or factual in the view of Brown v. Commissioner, 85 T.C. 968 (1985), affd. sub nom. Sochin v. Commissioner, 843 F.2d 351 (9th Cir. 1988). … Braunstein, Ronald and Ester Breslow, Howard and Nancy Brown, Estate of Jerome Casser, deceased, Barry Casser, executor, Estate of Charlotte Casser, deceased, Barry Casser, executor, Peter B.

Bick v. Commissioner

37 T.C.M. 1591 · United States Tax Court · Sep 28, 1978

Then he went to New York, where he boarded a freighter to Europe. In Europe, John first traveled to the site of the West German real property and vinelands. … See Brown v. Commissioner, 40 T.C. 861 , 869-70 (1963) , and Frank v. Commissioner, 20 T.C. 511 (1953) . 2 See also Dean v.

Brubaker v. Commissioner

28 T.C. 1281 · United States Tax Court · Sep 30, 1957

At a meeting of the board of directors of Joliet Properties, Inc., on November 26, 1946, Brubaker, who had been secretary, became president. … Graham Mill & Elevator Co. v. Thomas, (C. A. 5, 1945) 152 F. 2d 564 ; Rockford Varnish Co., 9 T. C. 171 ; sec. 117 (a) (1), I. R. C. 1939.

Hitchcock v. Commissioner

12 T.C. 22 · United States Tax Court · Jan 24, 1949

The principle applicable to the taxability of a family partnership of the type presented in the present case was concisely stated in Belcher v. … It is also interesting' to note in passing that the District Court for the Fourth Judicial District of Minnesota, in State of Minnesota v.

R. D. Merrill Co. v. Commissioner

4 T.C. 955 · United States Tax Court · Mar 7, 1945

The Board relied upon First Savings Bank of Ogden v. … Rheinstrom v. Conner, 125 Fed. (2d) 790.

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.

Facebook, Inc. & Subsidiaries

United States Tax Court · May 22, 2025

(v)(E). … Co. v.