Case law

Boyer v. Commissioner

58 T.C. 316 · United States Tax Court · May 17, 1972

Darco Realty Corp. v. Commissioner, 301 F. 2d 190 (C.A. 2, 1962), affirming a Memorandum Opinion of this Court; Kaltreider v. … See Kaltreider v. Commissioner, supra; Robert W. Pointer, supra; Browne v. United States, 174 Ct. Cl. 523 , 356 F. 2d 546 (1966).

Calcutt v. Commissioner

84 T.C. 716 · United States Tax Court · Apr 15, 1985

Welch v. Helvering, 290 U.S. 111 (1933); Rule 142(a). … See, e.g., Blum v. Commissioner, 59 T.C. 436 (1972).

Standard Tube Co. v. Commissioner

26 T.C. 915 · United States Tax Court · Aug 13, 1956

The Standard Tube Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Standard Tube Co. v. Commissioner Docket No. 33386 United States Tax Court 26 T.C. 915 ; 1956 U.S. Tax Ct. … He worked directly under V. O. Johnstone, petitioner's director of sales. Heffron worked entirely *128 on a salary basis.

Gold Kist v. Commissioner

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

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

Keck v. Commissioner

49 T.C. 313 · United States Tax Court · Jan 2, 1968

In Commissioner v. … In Commissioner v.

American Bemberg Corp. v. Commissioner

10 T.C. 361 · United States Tax Court · Feb 25, 1948

A. 1002; Zimmern v. Commissioner, 28 Fed. (2d) 769, reversing 9 B. T. A. 1382; and Buckland v. United States, 66 Fed. Supp. 681. … V. Burnell, vice president of Stone & Webster, on or about April 15, 1944, and Burnell’s testimony at the hearing.

Keith A. Tucker & Laura B. Tucker v. Commissioner

2017 T.C. Memo. 183 · United States Tax Court · Sep 18, 2017

Ruble when he was preparing the two Brown & Wood opinions. The two Brown & Wood opinions concluded Mr. … The board of directors had advised Mr. Tucker that if he did not resign, he would be fired.

Pied Piper Shoe Co. v. Commissioner

28 T.C. 499 · United States Tax Court · May 28, 1957

management and supervision of its business was assigned to another shoe manufacturer, Huth & James, which was a substantial stockholder at that time in petitioner and which was represented by some of its officers on petitioner’s board … Sherman & Ellis, Inc. v. Indiana Mutual Casualty Co., (C. A. 1, 1930) 41 F. 2d 588 .

Hope v. Commissioner

55 T.C. 1020 · United States Tax Court · Mar 22, 1971

Sohio Corporation v. … Lewis, 340 U.S. 590 (1951); Burnet v. Sanford & Brooks Co., 282 U.S. 359 (1931); Commissioner v. Brooklyn Union Gas Co., supra. 2.

Estate of C.S. Brasington, Burns v. Commissioner

12 T.C.M. 1482 · United States Tax Court · Dec 31, 1953

Burns, Jr., and Clayton Brown Brasington. Clayton Brown Brasington has two sons, Clayton Brown Brasington, Jr., and Lloyd Brasington. … Helvering v. Mitchell, 303 U.S. 391 .

Advertisers Exchange, Inc. v. Commissioner

25 T.C. 1086 · United States Tax Court · Feb 24, 1956

C. 247 ; United States v. Mitchell, 271 U. S. 9 ; Cecil v. Commissioner, 100 F. 2d 896 . … Schram v. United States, 118 F. 2d 541 . See Brown v. Helvering, 291 U.

Superior Beverage Co. v. Commissioner

58 T.C. 918 · United States Tax Court · Aug 28, 1972

Superior Beverage Company of Marysville, Inc., et. al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent Superior Beverage Co. v. … Rptr. 592 ; Pepper v.

International Trading Co. v. Commissioner

57 T.C. 455 · United States Tax Court · Dec 28, 1971

Bank v. … See S.F.H., Inc., 53 T.C. 28 (1969); see also Commissioner v. Brown, 380 U.S. 563 (1965). Our touchstone is what was the purpose of the legislation.

Solt v. Commissioner

19 T.C. 183 · United States Tax Court · Nov 10, 1952

Helvering v. Taylor, 293 U. S. 507 , and it is incumbent upon us to do the best we can with the materials at hand. As the Court of Appeals for the Second Circuit said in Cohan v. … Decision will be entered v/nder Bule 50. SEC. 127. WAR LOSSES.

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.

Green Gas Del. Statutory Trust v. Comm'r

147 T.C. 1 · United States Tax Court · Jul 14, 2016

In 1999, RTC’s board of directors consisted of Mr. Calvert, Mr. Greenblatt, Mr. Jahelka, and Mr. Nichols.6 During 2005-07, RTC’s board of directors consisted of Mr. Nichols and Mr. Connolly. … See Graff v. Commissioner, 74 T.C. 743, 754 (1980) (citing Chrysler Corp. v. Brown, 441 U.S. 281, 311(1979)), aff’d, 673 F.2d 784 (5th Cir. 1982).

Main-Hammond Land Trust v. Commissioner

17 T.C. 942 · United States Tax Court · Dec 6, 1951

On the other hand, respondent points to Title Insurance & Trust Co. v. Commissioner (C. … A. 9, 1938), 100 F. 2d 482 , affirming a Memorandum Opinion, Board of Tax Appeals, entered March 31,1938, and contends that it is more clearly applicable in the instant situation.

Anaheim Union Water Co. v. Commissioner

35 T.C. 1072 · United States Tax Court · Mar 29, 1961

Anaheim Union Water Company, a corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent. Santa Ana River Development Company, a corporation, Petitioner, v. … In International Trading Co. v.

European Naval Stores Co. v. Commissioner

11 T.C. 127 · United States Tax Court · Aug 5, 1948

Higgins v. Commissioner, 312 U. S. 212 . … In Esmond Mills v. Commissioner, 132 Fed. (2d) 753; certiorari denied, 319 U.

Morse v. Commissioner

17 T.C. 1244 · United States Tax Court · Jan 28, 1952

In 1941 the board of directors of petitioner’s employer determined to provide a monthly income for petitioner upon his retirement. … C. 275 ; Oberwinder v. Commissioner, 147 F. 2d 255 ; Hubbell v. Commissioner, 150 F. 2d 516 ; Hackett v. Commissioner, 159 F. 2d 121 .)