Case law

Browne v. Commissioner

75 T.C.M. 1567 · United States Tax Court · Jan 12, 1998

Memo. 1998-14 UNITED STATES TAX COURT ALICE PAULINE BROWNE, A.K.A. A. PAULINE BROWNE, Petitioner v. … More importantly, petitioner was served with a notice on 3 See Browne v. Commissioner, 73 T.C. 723 (1980); Dandeneau v. Commissioner, T.C. Memo. 1971-128, affd. without published opinion sub nom.

Phelps v. Commissioner

62 T.C. 513 · United States Tax Court · Jul 15, 1974

United States v. McKeever, supra at 675 ; Williams v. United States, 338 F. 2d 286, 288 (C.A. D.C. 1964). … United States, supra at 288-289; United States v. Waldman, supra at 749 ; Brown v. United States, 58 F.R.D. 599, 604 (D. S.C. 1973). See and compare United States v.

Smith v. Commissioner

82 T.C. 705 · United States Tax Court · Apr 30, 1984

See Morrison v. Commissioner, 59 T.C. 248, 256 (1972); cf. Shepard v. … In fact, none of the shareholders had a right to commissions without a board vote to the contrary; their distribution of remaining sales profits only became a right annually upon the oral agreement of the board on how to

Spirella Co. v. Commissioner

5 T.C. 876 · United States Tax Court · Sep 28, 1945

The Spirella Company Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent Spirella Co. v. Commissioner Docket No. 5030 United States Tax Court 5 T.C. 876 ; 1945 U.S. Tax Ct. … See Helvering v. Alabama Asphaltic Limestone Co ., 315 U.S. 179 , 184 .

Clayton v. Commissioner

102 T.C. 632 · United States Tax Court · Apr 18, 1994

In DiMauro v. … In Crocker v.

Estate of Wood v. Commissioner

92 T.C. 793 · United States Tax Court · Apr 12, 1989

Wells Marine, Inc. v. Renegotiation Board, 54 T.C. 1189 (1970). … See, e.g., Walden v.

Benjamin v. Commissioner

44 T.C. 598 · United States Tax Court · Jul 20, 1965

Wardner v. Seventh Day Baptist Memorial Board, 232 Ill. 606 , 83 N.E. 1077 (1908). … Field,, supra, and on the several Illinois cases above cited, Henderson v. Blackburn, Walker v. Pritchard, and Wardner v. Seventh Day Baptist Memorial Board, in support of this argument.

Coon Run Fuel Co. v. Commissioner

20 T.C. 122 · United States Tax Court · Apr 21, 1953

Coon Run Fuel Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Coon Run Fuel Co. v. Commissioner Docket No. 37297 United States Tax Court 20 T.C. 122 ; 1953 U.S. Tax Ct. … C. 148 , affd. 200 F. 2d 552 ; Helvering v. Nebraska Bridge Supply & Lumber Co ., 312 U.S. 666 , following Helvering v. Hammel , 311 U.S. 504 ; McCarty, et al., Executors v.

Goldberg v. Commissioner

15 T.C. 10 · United States Tax Court · Jul 12, 1950

Our decision was affirmed by the Fifth Circuit, the court stating in its opinion as follows: * * * we agree with the Commissioner and the Board that Waddell’s death effecting an immediate dissolution of the partnership, caused … Carroll v. Com’r, 5 Cir., 70 F. 2d 806 .

Goldstein v. Commissioner

73 T.C. 164 · United States Tax Court · Oct 24, 1979

For the first 2 weeks of her assignment, petitioner was provided with room and board by a family in that community who were directly reimbursed by VISTA. … Higgins v.

Estate of Dillingham v. Commissioner

88 T.C. 1569 · United States Tax Court · Jun 25, 1987

McCarthy v. United States, 806 F.2d 129 (7th Cir. 1986), revg. 624 F. Supp. 763 (N.D. Ill. 1985); Bacchus v. United States, an unreported case (D. N.J. 1985, 57 AFTR2d 86-1519, 86-1 USTC par. 13,669 ); Cullis v. … See also Felder v. Felder, 71 Ga. App. 860 , 32 S.E.2d 550 (1944); In Re Brown’s Estate, 159 Kan. 408 , 155 P.2d 445 (1945).

Ruidoso Racing Asso. v. Commissioner

30 T.C.M. 792 · United States Tax Court · Aug 9, 1971

Petitioner, relying on Helvering v. … Brown, 18 B.T.A. 859 , 866-867 (1930) , certiorari denied 286 U.S. 556 (1932) . See also Hensley v. United States, 406 F. 2d 481 (C.A. 10, 1968), affirming the conviction of Eugene V.

Allen v. Commissioner

22 T.C. 70 · United States Tax Court · Apr 20, 1954

Clanton v. Oklahoma Tax Commission, 208 Okla. 92 , 253 P. 2d 562 ; Midyett v. Midyett, 206 Okla. 312 , 243 P. 2d 650 , as explained in Swanda v. Swanda, supra; Harmon v. … C. 1041, 1053 ; Hamilton-Brown Shoe Co. v. Lastinger, 26 S. W. 924 , 926 (Tex. Civ. App.); Gorman v. Gorman, 180 S. W. 2d 470 (Tex. Civ. App.); Trapp v. United States, 177 F. 2d 1, 6 (C. A. 10), certiorari denied 339 U.

E.J. Harrison & Sons, Inc. v. Comm'r

86 T.C.M. 240 · United States Tax Court · Aug 13, 2003

Nicoll Co. v. … Stations, Inc. v.

Blum v. Commissioner

5 T.C. 303 · United States Tax Court · Jun 21, 1945

Hill v. Commissioner, 126 Fed. (2d) 570; Cohen Trust v. Commissioner, 121 Fed. (2d) 689; Hammans v. Commissioner, 121 Fed. (2d) 4. … He testified at first that he received his instructions from the board of directors, through the president of the company, to open a treasury account and to mark the stock accordingly.

Carr v. Commissioner

37 T.C.M. 1695 · United States Tax Court · Oct 11, 1978

At the time of trial, Carr was a trustee of the Regional Transit Authority.During the taxable years at issue, he was President *112 of Quincy Savings and Loan Company (Quincy S&L) and a member of its Board of Directors. … Brown as the basis for the reported income and expenses from Carr's legal practice and rental properties.

Hooker Electrochemical Co. v. Commissioner

8 T.C. 1120 · United States Tax Court · May 27, 1947

Hooker Electrochemical Co., Petitioner, v. Commissioner of Internal Revenue, Respondent. Edwin R. Bartlett, Petitioner, v. Commissioner of Internal Revenue, Respondent. Harry M. Hooker, Petitioner, v. … Commissioner of Internal Revenue, Respondent Hooker Electrochemical Co. v. Commissioner Docket Nos. 10245, 10246, 10247 United States Tax Court 8 T.C. 1120 ; 1947 U.S. Tax Ct.

Auerbach Shoe Co. v. Commissioner

21 T.C. 191 · United States Tax Court · Nov 6, 1953

Burnet v. Harmel, 287 U. S. 103 (1932). … Joyce v. Gentsch, (C. A. 6, 1944) 141 F. 2d 891 . See Payson v. Commissioner, (C. A. 2, 1948) 166 F. 2d 1008 , and Bank of New York v. United States, (C. A. 3, 1948) 170 F. 2d 20 .

Lorain Ave. Clinic v. Commissioner

31 T.C. 141 · United States Tax Court · Oct 23, 1958

, a chairman of the board of trustees and a general manager. … V.

May Dep't Stores Co. v. Commissioner

16 T.C. 547 · United States Tax Court · Mar 1, 1951

Gregory v. Helvering, 293 U. S. 465 . A corporation may, within the statute, so conduct its affairs as to avoid or reduce tax burdens. United States v. Cumberland Public Service Co., 338 U. S. 451 . … He contends that the property had a fair market value of $1,300,000, the value placed upon the property by Wallerstedt in May 1948 when testifying before a Board of Reviewers of Allegheny County concerning assessments of