Case law

Southeastern Finance Co. v. Commissioner

4 T.C. 1069 · United States Tax Court · Mar 31, 1945

Home Bond Co. v. McChesney , 239 U.S. 568 ; and Commercial Security Co. v. … In Home Bond Co. v.

Rollins v. Commissioner

32 T.C. 604 · United States Tax Court · Jun 10, 1959

Higgins v. Commissioner, 312 U.S. 212 ; Commissioner v. Smith, supra; Wheeler v. Commissioner, supra; Thomas Reed Vreeland, supra. … Holtz v. Commissioner, supra.

S. C. Johnson & Son, Inc. v. Commissioner

63 T.C. 778 · United States Tax Court · Mar 31, 1975

Commissioner, 292 F.2d 478 (C.A. 3, 1961), affirming 34 T.C. 842 (1960); Hudspeth v. United States, 471 F.2d 275 (C.A. 8, 1972); Kinsey v. … See also Grove v. Commissioner, 490 F.2d 241 (C.A. 2, 1973), affirming a Memorandum Opinion of this Court; Behrend v. United States, an unreported case (C.A. 4, 1972, 31 AFTR 2d 73-406, 73-1 USTC par. 9123 ); DeWitt v.

Anchor Nat'l Life Ins. Co. v. Commissioner

93 T.C. 382 · United States Tax Court · Sep 28, 1989

On • December 11, 1980, petitioner’s board of directors adopted a resolution to amend the certificates to increase the interest payable on them. … As in Jones v. United States, supra, and Harlan v.

Bymaster v. Commissioner

20 T.C. 649 · United States Tax Court · Jun 24, 1953

Bymaster, Petitioner, v. Commissioner of Internal Revenue, Respondent Bymaster v. Commissioner Docket No. 35470 United States Tax Court 20 T.C. 649 ; 1953 U.S. Tax Ct. … See, also, Lapham v. United States , 178 F. 2d 994 .

Western Cartridge Co. v. Commissioner

11 T.C. 246 · United States Tax Court · Sep 13, 1948

Western Cartridge Company (Now: Olin Industries, Inc.), Petitioner, v. Commissioner of Internal Revenue, Respondent Western Cartridge Co. v. Commissioner Docket No. 9670 United States Tax Court 11 T.C. 246 ; 1948 U.S. … (See Chestnut Securities Co. v. United States , 62 Fed. Supp. 574 ). The accrual basis of accounting for liability items relates to deductibility of items which are unpaid. (Cf. Dixie Pine Products Co. v.

Coffey v. Commissioner

1 T.C. 579 · United States Tax Court · Feb 12, 1943

A. 927, the Board said that; It is well settled that before there can be a completed gift the donor must surrender dominion and control of the subject matter of it. Edson v. … S. 552 ; Jackson v. Commissioner, 64 Fed. (2d) 359; Dulin v. Commissioner, 70 Fed. (2d) 828.

Russell v. Commissioner

60 T.C. 942 · United States Tax Court · Sep 19, 1973

In Autenrieth v. … Justice Black, in Everson v. Board of Education, 1947, 330 U.S. 1 , 15-16 * * *) It taxes plaintiffs Hice all others, because they are citizens or residents who have taxable income. On matters religious, it is neutral.

King v. Commissioner

31 T.C. 108 · United States Tax Court · Oct 22, 1958

The Board also denied that the transaction represented a sale or exchange, and characterized it rather as a division of property. This was reversed by the Court of Appeals for the Third Circuit in Commissioner v. … Feves v. Feves, 198 Ore. 151 , 254 P. 2d 694, 700 .

Burgo v. Commissioner

69 T.C. 729 · United States Tax Court · Feb 21, 1978

Previously, Thomas lived with his mother who operated a boarding house. … In United States v.

Aiken Industries, Inc. v. Commissioner

56 T.C. 925 · United States Tax Court · Aug 5, 1971

Maximov v. United States, supra; Bacardi Corp. v. Domenech,, supra. … See Knetsch v. United States, 364 U.S. 361 (1960); Higgins v. Smith, 308 U.S. 473 (1940); Gregory v. Helvering, supra.

Fleming v. Commissioner

24 T.C. 818 · United States Tax Court · Jul 29, 1955

Petitioners cite Commissioner v. Crichton, 122 F. 2d 181 , affirming Kate J. Crichton, 42 B. T. … The difference in this respect from Midfield Oil Co., supra, is pointed out in the Board of Tax Appeals’ opinion in the Crichton case, supra. (See 42 B. T. A. at p. 492.) Petitioners rely on Fleming v. Campbell, (C.

Knoxville Iron Co. v. Commissioner

18 T.C.M. 251 · United States Tax Court · Mar 23, 1959

Olin Corporation v. Commissioner, 128 Fed. (2d) 185 , affirming 42 B.T.A. 1203 ; World Publishing Co. v. United States, 169 Fed. (2d) 186 . … KOMA, Inc. v. Commissioner, supra.

Southern Church of Universal Brotherhood Assembled, Inc. v. Commissioner

74 T.C. 1223 · United States Tax Court · Sep 10, 1980

Regular memberships are limited to 25 and consist of those persons elected by the board of trustees. Regular members are entitled to one vote at all membership meetings. … General Conference of the Free Church of America v. Commissioner, 71 T.C. 920 (1979); Johnson v. Robison, 415 U.S. 361 (1974); Gillette v. United States, 401 U.S. 437 (1971).

The Board of Trustees of the Sheet Metal Workers' National Pension Fund v. Commissioner

117 T.C. No. 19 · United States Tax Court · Dec 4, 2001

No. 19 UNITED STATES TAX COURT THE BOARD OF TRUSTEES OF THE SHEET METAL WORKERS’ NATIONAL PENSION FUND, IN ITS CAPACITY AS PLAN ADMINISTRATOR, Petitioner v. … In Hickey v.

Lake Erie & P. R. Co. v. Commissioner

5 T.C. 558 · United States Tax Court · Aug 6, 1945

The Lake Erie and Pittsburg Railway Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Lake Erie & P. R. Co. v. Commissioner Docket No. 3558 United States Tax Court 5 T.C. 558 ; 1945 U.S. Tax Ct. … A resolution was adopted by the board of directors of the petitioner at a meeting held on December 28, 1938, in which the modification of paragraph seventh of the agreement dated January 10, 1908, was approved.

Funk v. Commissioner

14 T.C. 198 · United States Tax Court · Feb 14, 1950

In Funk v. … Funk v. Commissioner, Board of Tax Appeals (now the Tax Court of the United States) Docket No. 111193, hereinafter called the Wilfred J.

Nachman v. Commissioner

12 T.C. 1204 · United States Tax Court · Jun 30, 1949

In Bonwit Teller & Co. v. … Decisions will be entered v/nder Rule 60.

Bishop v. Commissioner

25 T.C. 969 · United States Tax Court · Jan 31, 1956

The stipulation outlines much of the work done by the attorneys and states, in part : Abe Eugene Rosenberg and V. V. … Solimine v. Hollander, 19 A. 2d 344 (N. J.); State v. Bechtel, 56 N. W. 2d 173 (Ia.); Coeur D'Alenes Lead Co. v. Kingsbury, 59 Idaho 627 , 85 P. 2d 691 ; May v. Midwest Refining Co., 121 F. 2d 431 .

Mine & Smelter Supply Co. v. Commissioner

10 T.C. 1179 · United States Tax Court · Jun 24, 1948

The Mine and Smelter Supply Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Mine & Smelter Supply Co. v. Commissioner Docket No. 11609 United States Tax Court 10 T.C. 1179 ; 1948 U.S. Tax Ct. … On June 3, 1937, the petitioner's *160 board of directors held a special meeting in Denver for the purpose of considering the advisability of entering into the proposed contracts of employment with certain executives and