Case law

Budd v. Commissioner

7 T.C. 413 · United States Tax Court · Jul 30, 1946

Budd, Petitioner, v. Commissioner of Internal Revenue, Respondent Budd v. Commissioner Docket No. 8829 United States Tax Court 7 T.C. 413 ; 1946 U.S. Tax Ct. … Budd desire Robert Ralph Budd to attend a private boarding college preparatory school rather than High School, Robert W.

Falk v. Commissioner

15 T.C. 49 · United States Tax Court · Jul 31, 1950

Howard v. Carusi, 109 U. S. 725 ; Russell v. United States Trust Co.. 127 Fed. 445 . In Edgar R. Stix, 4 T. … A somewhat similar situation was presented in Loggie v. Thomas, 152 Fed. (2d) 636.

Grant Creek Water Works, Ltd. v. Commissioner

91 T.C. 322 · United States Tax Court · Aug 22, 1988

Adickes v. Kress & Co., supra at 157; United States v. Diebold, Inc., 369 U.S. 654, 655 (1962). … Lyons v. Board of Education of Charleston, 523 F.2d 340, 347 (8th Cir. 1975).

Hopcus v. Commissioner

55 T.C.M. 717 · United States Tax Court · Apr 28, 1988

Petitioner boarded horses for seven months during 1983 and also had boarders during 1984. Petitioners must prove that the Shortacre Stables expenses are properly deductible under either section 162 or 212. Welch v. … Allen v. Commissioner, 72 T.C. 28 , 34 (1979) . The burden of proof is on the taxpayer, Golanty v.

Day v. Commissioner

24 T.C.M. 1812 · United States Tax Court · Dec 29, 1965

At the time of the sale there were approximately 150,000 board feet of merchantable timber standing on the land. During this period timber was selling for $13.764 per thousand board feet. … Carter v. Campbell, 264 F. 2d 930 (C.A. 5, 1959); Cefalu v. Commissioner, 276 F. 2d 122 (C.A. 5, 1960).

Klein v. Commissioner

42 T.C. 1000 · United States Tax Court · Aug 31, 1964

Petitioners reported income on a cash basis at all times referred to herein. ifi i|* 5}s ■ v $ V ^ 5. … The Board rightly applied to them the law as it stood when the gains became taxable. It seems to us that Snell v. Commissioner, supra, is controlling here and we sustain the Commissioner.

Western Federal Sav. & Loan Asso. v. Commissioner

55 T.C.M. 372 · United States Tax Court · Mar 10, 1988

Frontier Savings Association v. … Estate of Lang v. Commissioner, 64 T.C. 404 , 406-407 (1975) , affd. 613 F.2d 770 (9th Cir. 1980) . Furthermore, in Frontier Savings Association v.

Rollingwood Corp. v. Commissioner

9 T.C.M. 597 · United States Tax Court · Jul 17, 1950

Rollingwood Corporation v. Commissioner. David D. Bohannon, Transferee v. Commissioner. Rollingwood Corp. v. Commissioner Docket Nos. 20002, 20003. United States Tax Court 1950 Tax Ct. Memo LEXIS 147 ; 9 T.C.M. … Brown, C.P.A., and Justin M. Jacobs, Esq., 403 Merchant Exchange Bldg., San Francisco, Calif., for the petitioners. Charles W. Nyquist, Esq., for the respondent.

Gunther v. Commissioner

92 T.C. 39 · United States Tax Court · Jan 19, 1989

See United States v. Gilmore, 372 U.S. 39, 44-45 (1963); Ziegler v. Commissioner, 70 T.C. 139, 143 (1978); Doing v. Commissioner, 58 T.C. 115, 129 (1972). See also J.C. Penney Co. v. … Rosado v. Wyman, 397 U.S. 397 (1970); Commissioner v. Brown, 380 U.S. 563 (1965); Worthy v. United States, 328 F.2d 386 (5th Cir. 1964). The law favors a rational and sensible construction. American Tobacco Co. v.

Runyon v. Commissioner

8 T.C. 350 · United States Tax Court · Feb 19, 1947

See Commissioner v. Tower, 327 U. S. 280 ; Lusthaus v. Commissioner, 327 U. S. 293 ; Ed Dubinsky Durwood, 6 T. C. 682 ; Floyd D. Akers, 6 T. C. 693 ; Abe Schreiber, 6 T. C. 707 ; W. A. Belcher, 7 T. C. 182 ; and John G. … This court In Bozeman v.

Maloof v. Comm'r

2005 T.C. Memo. 75 · United States Tax Court · Apr 6, 2005

Estate of Leavitt v. Commissioner, supra; Brown v. Commissioner, supra; Spencer v. Commissioner, supra; Calcutt v. Commissioner, 84 T.C. 716, 719- 720 (1985); Perry v. Commissioner, supra; Raynor v. … United States, 778 F.2d at 773; Brown v. Commissioner, supra; Framatome Connectors USA, Inc. v. Commissioner, 118 T.C. 32, 47 (2002), affd. 108 Fed. Appx. 683 (2d Cir. 2004).

Small v. Commissioner

3 T.C. 1142 · United States Tax Court · Jul 21, 1944

A. 346, and similar eases, the claim that the trust was on the latter ground covered by the provisions of section 167, the Board also concluded that the grantor was not taxable under section 22 (a). … It distinguished White v. Higgins (C. C.

Brant v. Commissioner

13 T.C. 712 · United States Tax Court · Nov 9, 1949

In Commissioner v. Speyer, 77 Fed. (2d) 824, and Commissioner v. Ullmann, 77 Fed. (2d) 827 (certiorari denied, 296 U. … In Drier v.

Kobacker v. Commissioner

37 T.C. 882 · United States Tax Court · Feb 8, 1962

United States v. Isham, 84 U.S. 496 ; Gregory v. Helvering, 293 U.S. 465, 469 ; United States v. Cumberland Pub. Serv. Co., 338 U.S. 451 ; Zenz v. … Zenz v. Quinlivan, supra; United States v. Cumberland Pub. Serv. Co., supra. On the other hand, as stated by the Supreme Court in Higgins v.

Christensen v. Commissioner

33 T.C. 500 · United States Tax Court · Dec 11, 1959

See De Guire v. Higgins, 159 F. 2d 921, 923 (C.A. 2, 1947). … See Mayer v. Donnelly and Estate of Arthur L. Hobson, both supra.

Ewing v. Commissioner

118 T.C. 494 · United States Tax Court · May 31, 2002

FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 132-133 (2000). … See FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 132-133 (2000).

Ottow v. Commissioner

68 T.C.M. 60 · United States Tax Court · Jul 13, 1994

JEFFREY OTTOW AND SHARON OTTOW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Ottow v. Commissioner Docket No. 236-93 United States Tax Court T.C. Memo 1994-319 ; 1994 Tax Ct. Memo LEXIS 328 ; 68 T.C.M. … Petitioners talked with other operators of horse-boarding businesses and learned that it was common practice for the operator of a stable to maintain his or her own horse with the boarded horses.

Schultz v. Commissioner

50 T.C. 688 · United States Tax Court · Jul 31, 1968

Corp. v. Board of Education, 256 S.W. 2d 481, 485 (Ky. App. 1952). … See Blansett v. United States, 283 F. 2d 474, 478 (C.A. 8, 1960); Bernstein v. Commissioner, 267 F. 2d 879, 881 (C.A. 5, 1959); Irish v. Commissioner, 129 F. 2d 468, 470 (C.A. 3, 1942).

Simmons v. Commissioner

72 T.C. 1204 · United States Tax Court · Sep 26, 1979

Simmons, Petitioners v. Commissioner of Internal Revenue, Respondent Simmons v. Commissioner Docket No. 4509-77 United States Tax Court 72 T.C. 1204 ; 1979 U.S. Tax Ct. … On June 14, 1973, Murteza's board of directors held a special meeting. The minutes of this meeting reflect that the following resolution was adopted: 5. That a plan whereby Donald C.

Peeler Hardware Co. v. Commissioner

5 T.C. 518 · United States Tax Court · Jul 28, 1945

Kennemer v. Commissioner, 96 Fed. (2d) 177, 178; Tootle v. Commissioner, 58 Fed. (2d) 576. … Peeler’s compensation was fixed by the board of directors of the corporation. We find that the salaries paid to T. B. Peeler for the years in question were reasonable. Decision will he entered under Rule 50. SEC. 717.