Case law

Duarte v. Commissioner

44 T.C. 193 · United States Tax Court · May 19, 1965

Subsequently, on January 5, 1959, a resolution was passed by the board of directors of Graham Corp. reducing petitioner’s salary from the $30,000 he had been receiving annually in 1956, 1957, and 1958, to $15,600. … See Gregory v. Helvering, 293 U.S. 465 ; Knetsch v. United States, 364 U.S. 361 . This has become a major principle of income tax law.

Shepherd Constr. Co. v. Commissioner

51 T.C. 890 · United States Tax Court · Mar 3, 1969

Both parties agree that this determination ultimately depends upon a proper application of the “all events” test established in United States v. … See Lucas v. American Code Co., 280 U.S. 445 (1930).

Leavens v. Commissioner

44 T.C. 623 · United States Tax Court · Jul 23, 1965

Such amendments are valid when there is delivered to the trustee a certified copy of a resolution of the board of directors authorizing such modification. … Freuler v. Helvering, 291 U.S. 35, 39 (1934); Blair v. Commissioner, 300 U.S. 5 (1937); Gallagher v. Smith, 223 F. 2d 218 (C.A. 3, 1955).

Lio v. Commissioner

85 T.C. 56 · United States Tax Court · Jul 24, 1985

Brown , for the petitioners. Judy Jacobs , for the respondent. Simpson , Judge . … Stravinsky 198/250 Chicago Board of Education 1. Mozart 156/250 2. Debussy 149/250 3. Bach 151/250 4. Mahler 151/250 5. Ravel 138/250 6.

Rand v. Commissioner

33 T.C. 548 · United States Tax Court · Dec 21, 1959

The petitioner was elected to the board of directors of International Shoe Company in 1951 or 1952. Rumer was elected to the board of directors of that company in 1950. … Kilpatrick v. Robert, 278 Mo. 257 , 212 S.W. 884 ; Cornet v. Cornet, supra; In re Estate of Mays, 197 Mo. App. 555 , 196 S.W. 1039 ; Fiske v. Buder, 8 Cir., 125 F. 2d 841, 847 .

Turtle Wax, Inc. v. Commissioner

43 T.C. 460 · United States Tax Court · Jan 26, 1965

Court of Claims on June 12,1964, in Charles Leich & Co. v. … United States v. Anderson, 269 U.S. 422 ; Brown v. Helvering, 291 U.S. 193 ; and Denver & Rio Grande Western Railroad Co., 38 T.C. 557, 572 .

Emmet v. Commissioner

11 T.C. 90 · United States Tax Court · Jul 28, 1948

Emmet, Petitioner, v. Commissioner of Internal Revenue, Respondent. H. L. R. Emmet, Petitioner, v. Commissioner of Internal Revenue, Respondent Emmet v. … The school board, however, refused to grant any exemption of taxes.

Waters v. Commissioner

3 T.C. 407 · United States Tax Court · Mar 6, 1944

Weiss v. Weiner , 279 U.S. 333 . *183 And, unlike Commissioner v. … See Helvering v. Wood , 309 U.S. 344 .

Record Realty Co. v. Commissioner

6 T.C. 823 · United States Tax Court · Apr 25, 1946

Record Realty Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Record Realty Co. v. Commissioner Docket No. 4292 United States Tax Court 6 T.C. 823 ; 1946 U.S. Tax Ct. … declined to follow the Circuit Court's view, but applied the rule stated in the Hershey ↩ case before the Board, in . 2.

Reinhardt v. Commissioner

75 T.C. 47 · United States Tax Court · Oct 8, 1980

California Sanitary Co. v. Commissioner, 32 B.T.A. 122 (1935); Crown Zellerbach Corp. v. Commissioner, supra. … Co. v. State, 31 Cal. 2d 391 , 189 P.2d 262 (1948). Penalties being nondeductible (Achelis et al., Executors v.

Furman v. Commissioner

45 T.C. 360 · United States Tax Court · Jan 10, 1966

Brown v. Commissioner, 180 F. 2d 926 (C.A. 3, 1950), reversing 12 T.C. 1095 (1949), certiorari denied 340 U.S. 814 ; Skemp v. Commissioner, 168 F. 2d 598 (C.A. 7, 1948), reversing 8 T.C. 415 (1947); John T. … In Barber v.

Lisle v. Commissioner

35 T.C.M. 627 · United States Tax Court · May 4, 1976

Jordan Co. v. Allen, 85 F. Supp. 437 , 443 ( M.D. Ga. 1949 ) . … Mountain State Steel Foundries, Inc. v.

Bankers Mortg. Co. v. Commissioner

1 T.C. 698 · United States Tax Court · Mar 2, 1943

Bankers Mortgage Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Bankers Mortg. Co. v. Commissioner Docket No. 106993 United States Tax Court 1 T.C. 698 ; 1943 U.S. Tax Ct. … Exhibit one is a copy of resolution adopted by the board of directors of the Bankers Mortgage Co., Houston, Texas, on June 9, 1937.

Taylor v. Commissioner

16 T.C. 376 · United States Tax Court · Feb 19, 1951

Taylor, Petitioner, v. Commissioner of Internal Revenue, Respondent Taylor v. Commissioner Docket No. 25753 United States Tax Court 16 T.C. 376 ; 1951 U.S. Tax Ct. LEXIS 277 ; 88 U.S.P.Q. … Thomas V. Lefevre, Esq ., for the respondent. Tietjens , Judge .

Tucker v. Commissioner

55 T.C. 783 · United States Tax Court · Feb 23, 1971

In Commissioner v. … See Commissioner v. Flowers, supra.

Mid-State Products Co. v. Commissioner

21 T.C. 696 · United States Tax Court · Feb 15, 1954

Mid-State Products Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Mid-State Products Co. v. Commissioner Docket No. 24793 United States Tax Court 21 T.C. 696 ; 1954 U.S. Tax Ct. … In Real Estate-Land Title & Trust Co. v.

Stephanie Murrin

United States Tax Court · Jan 24, 2024

Memo. 2012- 194, 2012 WL 2865875, at *7; Browning v. Commissioner, T.C. Memo. 2011-261, 2011 WL 5289636, at *13 n.14; cf. City Wide Transit, Inc. v. … Memo. 2013-176, at *19–21 (same); Eriksen v. Commissioner, 2012 WL 2865825, at *12 (same); City Wide Transit, Inc. v. Commissioner, 2011 WL 5884981, at *6 (same); Browning v.

Barnette v. Commissioner

64 T.C.M. 998 · United States Tax Court · Oct 5, 1992

In disregarding a stipulation as to the deductibility of an item, the Board of Tax Appeals said, in Ohio Cloverleaf Dairy Co. v. … To *632 this the Board replied: This goes beyond the function of the Board.

Acquisto v. Commissioner

62 T.C.M. 44 · United States Tax Court · Jul 2, 1991

ACQUISTO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Acquisto v. Commissioner Docket No. 6124-90 United States Tax Court T.C. Memo 1991-293 ; 1991 Tax Ct. Memo LEXIS 339 ; 62 T.C.M. (CCH) 44 ; T.C.M. … Paul Aquisto (petitioner) was employed as a school teacher by the School Board of Lee *340 County (School Board) from August of 1967 until his retirement in June of 1986.

Estate of Wanamaker v. Commissioner

1 T.C.M. 809 · United States Tax Court · Mar 23, 1943

In reaching our *412 conclusion in the Bradley case, we relied upon numerous court decisions, among them being Brown et al., Executors v. United States (unreported). … Since rendition of our opinion in the Bradley case the Circuit Court of Appeals for the Ninth Circuit, in affirming the Brown case, observed that "the current of decisions has doubtless encompassed May v.