Case law

Estate of Ming v. Commissioner

35 T.C.M. 522 · United States Tax Court · Apr 15, 1976

v. … Ming also participated in the following cases: Hale v. Kentucky, 303 U.S. 613 ; Missouri ex rel Gaines v. Canada, 305 U.S. 337 ; Smith v. Allwright, 321 U.S. 649 ; Lyons v. Oklahoma, 322 U.S. 596 ; Sipuel v.

Maynard Hospital, Inc. v. Commissioner

52 T.C. 1006 · United States Tax Court · Sep 25, 1969

Maynard Hospital, Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent Maynard Hospital, Inc. v. … See Commissioner v. Battle Creek, Inc ., 126 Fed (2d) 405 . 2.

Auto Finance Co. v. Commissioner

24 T.C. 416 · United States Tax Court · Jun 17, 1955

Auto Finance Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Auto Finance Co. v. Commissioner Docket No. 52753 United States Tax Court 24 T.C. 416 ; 1955 U.S. Tax Ct. … Zenz v. Quinlivan , (C. A. 6, 1954) 213 F. 2d 914 , followed. O. R. McGuire, Jr., Esq ., and Richard A. Mullens, Esq ., for the petitioner. Ralph V. Bradbury, Jr., Esq ., for the respondent. Fisher , Judge .

Andrews v. Commissioner

23 T.C. 1026 · United States Tax Court · Mar 15, 1955

See Brown v. Helvering, 291 U. S. 193 (1934); North American Oil v. Burnet, 286 U. S. 417 (1932). … North American Oil v. Burnet, supra.

Kaye v. Commissioner

33 T.C. 511 · United States Tax Court · Dec 16, 1959

Compare Goodstein v. Commissioner, 267 F. 2d 127 , and Broome v. United States, supra. Bookkeeping entries are not conclusive. Doyle v. Mitchell Bros. Co., 247 U.S. 179 . … Brown v. Commissioner, 241 F. 2d 827 ; Broome v. United States, supra; and Goodstein v. Commissioner, supra. What petitioners paid CanFitz was not an amount paid “for the use of borrowed money,” Old Colony R. Co. v.

New England Lime Co. v. Commissioner

13 T.C. 799 · United States Tax Court · Nov 28, 1949

New England Lime Company, Petitioner, v. Commissioner of Internal Revenue, Respondent New England Lime Co. v. Commissioner Docket No. 18055 United States Tax Court 13 T.C. 799 ; 1949 U.S. Tax Ct. … A plan was approved by the board of directors on October 28, 1941. Steps were taken to arrange for an exchange of preferred stock for debenture bonds to be issued by the petitioner.

Oppenheimer Casing Co. v. Commissioner

22 T.C.M. 1082 · United States Tax Court · Aug 15, 1963

Oppenheimer Casing Co. v. Commissioner. Oppenheimer Casing Co. v. Commissioner Docket No. 95397. United States Tax Court T.C. Memo 1963-216 ; 1963 Tax Ct. Memo LEXIS 128 ; 22 T.C.M. (CCH) 1082 ; T.C.M. … The respondent, relying on Lengsfield v.

Fortee Properties, Inc. v. Commissioner

19 T.C. 99 · United States Tax Court · Oct 28, 1952

The Commissioner cites Crane v. Commissioner, 331 U. … United States v. Ludey, 274 U. S. 295 .

Georgia Fed. Bank, F.S.B. v. Commissioner

98 T.C. 105 · United States Tax Court · Feb 4, 1992

In that case, where the National Labor Relations Board had consistently interpreted the Taft-Hartley Act of 1947 as excluding “managerial employees”, the Supreme Court concluded that Congress' failure, when it amended the … People’s Federal Savings & Loan Association of Sidney v.

B.H.W. Anesthesia Foundation, Inc. v. Commissioner

72 T.C. 681 · United States Tax Court · Jul 24, 1979

Compare Sonora Community Hospital v. Commissioner, supra; Lorain Avenue Clinic v. Commissioner, supra. … As we stated in Lowry Hospital Association v.

First Nat'l Bank of McAllen v. Commissioner

9 T.C.M. 166 · United States Tax Court · Mar 6, 1950

First National Bank of McAllen v. Commissioner. First Nat'l Bank of McAllen v. Commissioner Docket No. 23926. United States Tax Court 1950 Tax Ct. Memo LEXIS 259 ; 9 T.C.M. (CCH) 166 ; T.C.M. … Effective with the change in ownership there was a change in the policy of operating petitioner whereby the board of directors of petitioner bank became an active board with a resultant increase in the directors' duties.

Glowinski v. Commissioner

25 T.C. 934 · United States Tax Court · Jan 31, 1956

Glowinski, Petitioner, v. Commissioner of Internal Revenue, Respondent Glowinski v. Commissioner Docket No. 55187 United States Tax Court 25 T.C. 934 ; 1956 U.S. Tax Ct. … Section 272 (g) of the Internal Revenue Code of 1939 so provides: (g) Jurisdiction Over Other Taxable Years. -- The Board in redetermining a deficiency in respect of any taxable year shall consider *281 such facts with relation

Sperling v. Commissioner

20 T.C. 1014 · United States Tax Court · Sep 17, 1953

Upon these facts, the Board held that the $5,000 which was paid Dippy to get him out of the firm and which was not paid him as a part of the price for his capital interest in the partnership was deductible as a business expense … The situation is not unlike that presented to the Supreme Court in Kornhauser v. United States, 276 U. S. 145 ; 48 S. C. 219; 6 Am. Fed. Tax.

Challenge Mfg. Co. v. Commissioner

37 T.C. 650 · United States Tax Court · Jan 10, 1962

the vessel was away from its home port, cruises made around Newport Harbor, guests who were on board while the vessel was in motion, persons who came on board at some of the places visited, fishing, swimming, drinking, and … During some of the days in 1956 and 1957 when Gallant Lady V was away from its home dock on trips there were guests on board that had some connection with the business of the corporate taxpayer; however, their presence on

Roehl Construction Co. v. Commissioner

17 T.C. 1037 · United States Tax Court · Dec 26, 1951

Eoehl, the petitioner’s secretary-treasurer and general manager, who testified that rentals and salaries were paid in the amounts as set out in the resolutions by the board of directors, but that in his opinion the rental … Helvering v. Tex-Penn Oil Co., 300 U. S. 481 ; Whitehead v. Commissioner, 64 F. 2d 118 , certiorari denied 290 U. S. 690 ; John A. Nelson Co., 28 B. T. A. 529; Doyle v. Mitchell Bros. Co., 247 U. S. 179 .

Oregon Pulp & Paper Co. v. Commissioner

34 T.C. 624 · United States Tax Court · Jun 30, 1960

Oregon Pulp and Paper Company, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Oregon Pulp & Paper Co. v. Commissioner Docket No. 79826 United States Tax Court 34 T.C. 624 ; 1960 U.S. Tax Ct. … On December 14, 1954, and December 21, 1955, petitioner's board of directors adopted resolutions waiving and forgiving the interest to its subsidiary for the respective taxable years.

Georgia-Pacific Corp. v. Commissioner

63 T.C. 790 · United States Tax Court · Mar 31, 1975

Miller’s Estate v. … Commissioner v. South Texas Co., 333 U.S. 496, 501 . See also Bingler v. Johnson, 394 U.S. 741, 749-750 ; Fawcus Machine Co. v. United States, 282 U.S. 375, 378 ; Boskev. Comingore, 177 U.S. 459, 470 ; Brewster v.

Kamin Chevrolet Co. v. Commissioner

3 T.C. 1076 · United States Tax Court · Jul 10, 1944

In Helvering v. … . * * * See also Helvering v.

T.J. ENTERPRISES v. COMMISSIONER OF INTERNAL REVENUE

101 T.C. 581 · United States Tax Court · Dec 16, 1993

INDOPCO, Inc. v. Commissioner, 503 U.S. _ , _, 112 S. Ct. 1039, 1044 (1992) (quoting Deputy v. du Pont, 308 U.S. 488, 495 (1940)); see Boser v. … Commissioner, 8 B.T.A. 737 (1927), and that the board had reached similar conclusions in those cases. See also Fairmont Homes, Inc. v. Commissioner, T.C.

Roschuni v. Commissioner

29 T.C. 1193 · United States Tax Court · Mar 31, 1958

Officially, she was the president, treasurer, and a member of the board of directors of each of the corporations. Her husband became the vice president of these corporations in January 1948. … Bank v. Burnet, 63 F. 2d 131 (C. A., D. C., 1933) affirming 23 B. T. A. 1304 (1931); Roy J. Kinnear, 36 B. T. A. 153 (1937); C. W. Murchison, 32 B. T. A. 32 (1935).