Case law

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 .

Granberg Equipment, Inc. v. Commissioner

11 T.C. 704 · United States Tax Court · Oct 28, 1948

Granberg Equipment, Incorporated (Now Known as Granberg Corporation), Petitioner, v. Commissioner of Internal Revenue, Respondent Granberg Equipment, Inc. v. … Commissioner v. Ashland Oil & Refining Co ., 99 Fed. (2d) 588 ; certiorari denied, 306 U.S. 661 ; Diescher v. Commissioner , 110 Fed. (2d) 90 ; certiorari denied, 310 U.S. 650 ; Helvering v.

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.

Urgent Care Nurses Registry, Inc. v. Comm'r

112 T.C.M. 480 · United States Tax Court · Nov 2, 2016

Petitioner was incorporated in California on July 21, 2005, and was assigned a taxpayer identification number by the California Franchise Tax Board (board). … Rev. & Tax Code sec. 23301 (West 2015); Grell v. Laci Le Beau Corp., 87 Cal. Rptr. 2d 358, 362 (Ct. App. 1999) (citing Reed v. Norman, 309 P.2d 809, 812 (Cal. 1957)).

Hilliker v. Commissioner

31 T.C.M. 896 · United States Tax Court · Aug 22, 1972

Hilliker v. Commissioner. Hilliker v. Commissioner Docket No. 5823-68. United States Tax Court T.C. Memo 1972-183 ; 1972 Tax Ct. Memo LEXIS 74 ; 31 T.C.M. (CCH) 896 ; T.C.M. … For the week ended August 28, 1965, the newsletter states "Charley Brown was on board for a few days - understand he was tabulating the number of new residents moving into the 'medium' size towns in the Florida area."

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.

Stillman v. Commissioner

60 T.C. 897 · United States Tax Court · Sep 17, 1973

Cl. 1973); Greer v. Commissioner, 334 F. 2d 20 (C.A. 5, 1964), affirming a Memorandum Opinion of this Court; Tomlinson v. … In support of this position, petitioners cite Carver v. United States, 412 F. 2d 233 (Ct.

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).

Kuckenberg v. Commissioner

35 T.C. 473 · United States Tax Court · Dec 30, 1960

In United States v. … United, States v. Garfunkel, 52 Fed. (2d) 727; Helen Dean Wright, 28 B.T.A. 543 .

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) .

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.

Robinette v. Comm'r

123 T.C. 85 · United States Tax Court · Jul 20, 2004

Since its enactment in 1946, the APA has never governed proceedings in this Court (or in its predecessor, the Board of Tax Appeals), and there is no indication that, in enacting section 6330, Congress intended to change this … See Ewing v. Commissioner, 122 T.C. 32, 50 (2004) (Thornton, J., concurring); see also O’Dwyer 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.

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.

Aviation Club of Utah v. Commissioner

7 T.C. 377 · United States Tax Court · Jul 17, 1946

The Aviation Club of Utah, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Aviation Club of Utah v. Commissioner Docket No. 9038 United States Tax Court 7 T.C. 377 ; 1946 U.S. Tax Ct. … No member or officer of the petitioner received any salary except one, an accountant who acted as clerk of the board and kept the books.

Doak v. Commissioner

24 T.C. 569 · United States Tax Court · Jun 30, 1955

Doak, Petitioners, v. Commissioner of Internal Revenue, Respondent Doak v. Commissioner Docket No. 52191 United States Tax Court 24 T.C. 569 ; 1955 U.S. Tax Ct. … Board and lodging furnished the daughter as an employee were ordinary and necessary expenses of the business. The present case is decided for the *571 petitioner upon authority of the Papineau case.

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

Federal Nat'l Mortg. Asso. v. Commissioner

90 T.C. 405 · United States Tax Court · Mar 14, 1988

Petitioner’s board of directors approved the proposed program in June 1980. A. … As this Court stated in Groetzinger v.

MacMurray v. Commissioner

21 T.C. 15 · United States Tax Court · Oct 9, 1953

See, e. g., Lucas v. Earl, 281 U. S. 111 ; Helvering v. Clifford, 309 U. S. 331 ; Harold G. Parker, 39 B. T. A. 423. … He quoted with approval from the dissenting opinion of Member Lansdon. of the Board of Tax Appeals in George D. Widener, 8> B. T.