Case law

Broadhead Trust v. Commissioner

31 T.C.M. 975 · United States Tax Court · Sep 7, 1972

Morrison also took into account the fact that the Pierce-Williams lands contained 30,000,000 board feet of timber at decedent's death and his discussions with Joe Brown in the summer of 1964. … Brown. The agreement provided for Joe L. Brown to cut 3,000,000 board feet 989 of timber each year for a 10-year period and to pay $120,000 per year for each of the 10 years.

Peerless Inv. Co. v. Commissioner

58 T.C. 892 · United States Tax Court · Aug 28, 1972

On December 8, 1949, the board of directors of the petitioner held a meeting at which the acquisition of control of the facilities of Packing was discussed. … Webster Investors, Inc. v. Commissioner, 291 F. 2d 192 (C.A. 2, 1961), affirming a Memorandum Opinion of this Court; cf. Redman L. Turner, 47 T.C. 355 (1967); The Pevely Dairy Co., 1 B.T.A. 385 (1925).

Steubenville Bridge Co. v. Commissioner

11 T.C. 789 · United States Tax Court · Nov 8, 1948

As was said by Judge Hand in Chisholm v. … Meurer Steel Barrel Co. v. Commissioner, 144 Fed. (2d) 282. In this decision the court distinguished Chisholm v.

C. P. A. Co. v. Commissioner

7 T.C. 912 · United States Tax Court · Oct 2, 1946

The petitioner relies upon Massachusetts Protective Association, Inc. v. United States, 114 Fed. (2d) 304. … Equitable Life Assurance Society v. Commissioner, 1935, 33 B. T.

Standard Oil Co. v. Commissioner

11 T.C. 843 · United States Tax Court · Nov 29, 1948

Standard Oil Company of New Jersey, Petitioner, v. Commissioner of Internal Revenue, Respondent Standard Oil Co. v. Commissioner Docket No. 7512 United States Tax Court 11 T.C. 843 ; 1948 U.S. Tax Ct. … See Jenkins v. National Surety Co ., 277 U.S. 258 ; American Surety Co. v. Westinghouse Electric Mfg. Co ., 296 U.S. 133 ; Pou v. South Carolina Warehousing Corporation , 27 Fed. (2d) 418 .

Meier v. Commissioner

2 T.C. 458 · United States Tax Court · Jul 21, 1943

Meier, Petitioner, v. Commissioner of Internal Revenue, Respondent Meier v. Commissioner Docket No. 112332 United States Tax Court 2 T.C. 458 ; 1943 U.S. Tax Ct. … During 1940 she was, and still is, employed in the capacity of charge nurse at Valley View Sanitarium, Paterson, *100 New Jersey, a tuberculosis hospital under the jurisdiction of the Board of Freeholders of Passaic County

West Missouri Power Co. v. Commissioner

18 T.C. 105 · United States Tax Court · Apr 23, 1952

See also City Bank Farmers Trust Co. v. Hoey, 52 F. … We think, to use the language of District Judge Clancy in City Bank Farmers Trust Co. v.

Estate of Cranor v. Commissioner

81 T.C.M. 1111 · United States Tax Court · Feb 8, 2001

See Commissioner v. Soliman, 506 U.S. 168, 174 (1993); Commissioner v. Brown, 380 U.S. 563, 570- 572 (1965). … See, e.g., Estate of Cerrito v. Commissioner, 73 T.C. 896 (1980); C. Frederick Brave, Inc. v. Commissioner, 65 T.C. 1001 (1976); Hoffman v. Commissioner, 63 T.C. 638 (1975); Axe v.

Shebester v. Commissioner

53 T.C.M. 824 · United States Tax Court · May 11, 1987

In Perry v. … See Underwood v. Commissioner, 535 F.2d at 312 n.2 ; see also Brown v. Commissioner 706 F.2d 755 , 756 (6th Cir. 1983) . To reflect the foregoing, Decision will entered under Rule 155. Footnotes 1.

Cohen v. Secretary of War

7 T.C. 1002 · United States Tax Court · Oct 22, 1946

See Abrath v. N. E. Ry. Co., L. R. 11; Q. B. Div. 440, 455; 11 A. C. 247; Jones, “The Law of Evidence,” 3d ed., 238; Thayer, “A Preliminary Treatise on Evidence,” 357, 358; Pennsylvania Railroad Co. v. … S. 333, 339 ; District of Columbia v. Vignau (App. D. C.), 144 Fed. (2d) 641.

Estate of Craft v. Commissioner

68 T.C. 249 · United States Tax Court · May 24, 1977

Commissioner, 58 T.C. 32, 39 (1972); Estate of O’Brien v. Commissioner, 57 T.C. 27, 30-31 (1971); Brown v. Commissioner, 52 T.C. 50, 60 (1969); Schmitz v. Commissioner, 51 T.C. 306, 317 (1968), affd. sub nom. … Estate of O’Brien v. Commissioner, supra; Brown v. Commissioner, supra; Harrison v. Commissioner, supra.

Rosenstein v. Commissioner

32 T.C. 230 · United States Tax Court · Apr 28, 1959

The taxpayer in O'Laughlin v. … See also Birnbaum v. Commissioner, 117 F. 2d 395 (C.A. 7, 1941).

Dutton v. Comm'r

122 T.C. 133 · United States Tax Court · Feb 11, 2004

Brown v. Commissioner, T.C. Memo. 2002-187 . Thus, we do not consider petitioner’s claim for relief under section 6013(e). II. … United States v. Donovan, 348 F.3d 509, 512-513 (6th Cir. 2003); Roberts v. United States, 242 F.3d 1065 (Fed. Cir. 2001); Timms v. United States, supra at 833-836; United States v.

Stemkowski v. Commissioner

76 T.C. 252 · United States Tax Court · Feb 17, 1981

In Korfund Co. v. … Fountain v. Commissioner, supra; Heidt v. Commissioner, supra.

Hart v. Commissioner

2 T.C. 1246 · United States Tax Court · Dec 29, 1943

An appeal to the Board of Tax Appeals was taken by the Comstock estate and settled by a stipulation that there was a deficiency of $750. … Commissioner v. Fletcher Savings & Trust Co., 59 Fed. (2d) 508. The draftsmanship is poor. Cf. Paul, Federal Estate and Gift Taxation, vol. 1, p. 637.

Gus Russell, Inc. v. Commissioner

36 T.C. 965 · United States Tax Court · Sep 12, 1961

On March 29, 1955, Composition’s board of directors resolved to exercise the option and so notified Gus. … See also United States v. Safety Car Heating Co., 297 U.S. 88, 98 (1936). In Television Industries, Inc. v.

Jeffries v. Commissioner

5 T.C. 1338 · United States Tax Court · Dec 28, 1945

Moline Properties, Inc. v. Commissioner , 319 U.S. 436 . 2. … The Board decided that upon Mrs.

Knight v. Commissioner

6 T.C. 90 · United States Tax Court · Jan 22, 1946

.; Walker v. Brown, 36 O. App. 463 ; 173 N. E. 301 . Once he expressed his choice, he had no further election. 2 Pomeroy, supra, sec. 516; 28 C. J. S. 1101, sec. 29; Hopf v. United States Baking Co., 6 Misc.

Schwehm v. Commissioner

17 T.C. 1435 · United States Tax Court · Feb 29, 1952

See Hess v. Gowen, 11 A. 2d 787 (Super. Ct. Pa. 1940); Western National Bank of York v. Levin, 200 A. 71 , 831 Pa. 113 (1938). … The minutes of a meeting of the board of directors of the Bank held on June 18,1930, show the following: Upon motion, resolved that we grant an extension of six months on loan of Ernest Schwehm for $125,000, providing $40,000

Thornton v. Commissioner

5 T.C. 116 · United States Tax Court · May 22, 1945

The Supreme Court said in Higgins v. … Helvering , 293 U.S. 465 ; Helvering v. Griffiths , 308 U.S. 355 ; Helvering v. Clifford , 309 U.S. 331 ; and Commissioner v. Court Holding Co ., 324 U.S. 331 .