Case law

Streiff v. Commissioner

77 T.C.M. 1565 · United States Tax Court · Mar 23, 1999

See Spiegelman v. Commissioner, 102 T.C. 394 (1994). … Board certification is awarded by the American Board of Internal Medicine (Board).

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.

Sorensen v. Commissioner

22 T.C. 321 · United States Tax Court · May 17, 1954

Wanda V. Van Dusen, 8 T. C. 388 , affd. 166 F. 2d 647 . … (See Commissioner v. John H. Smith, 324 U. S., 177 , Ct. D. 1633, C. B. 1945, 49; Old Colony Trust Co. v. Commissioner, 279 U. S., 716 , Ct. D. 80, C. B.

Anderson v. Commissioner

44 T.C.M. 1305 · United States Tax Court · Sep 30, 1982

Drucker v. Commissioner, supra at 14 of Slip Opinion; Green v. Commissioner, supra at 433 ; Jackson v. Commissioner, supra at 700 ; Baie v. … However, the Form 4835, Farm Rental Income and Expenses, for 1976 listed both the 80 acres in Phelps County and the 40 acres in Brown County. The Form 4835 for 1977 listed the 40 acres in Brown County.

Beckett v. Commissioner

41 T.C. 386 · United States Tax Court · Dec 20, 1963

Beckett, et al., * Petitioners, v. Commissioner of Internal Revenue, Respondent Beckett v. Commissioner Docket Nos. 95309, 95310, 95311 United States Tax Court 41 T.C. 386 ; 1963 U.S. Tax Ct. … Petitioners, however, contend that Libson Shops, Inc. v.

Cluff v. Commissioner

17 T.C. 225 · United States Tax Court · Aug 20, 1951

Cluff, Petitioner, v. Commissioner of Internal Revenue, Respondent Cluff v. Commissioner Docket No. 26130 United States Tax Court 17 T.C. 225 ; 1951 U.S. Tax Ct. … Burnet v. Logan, supra ; Commissioner v. Moore, supra .

Entertainment Sys. v. Commissioner

70 T.C.M. 460 · United States Tax Court · Aug 21, 1995

Co. v. … Brown v.

Graham v. Commissioner

26 T.C. 730 · United States Tax Court · Jun 29, 1956

Matthews never attended meetings of the board and the petitioner attended only occasionally. … Waterman v. Mackenzie , 138 U.S. 252 ; Kronner v. United States , (Ct. Cl.) 110 F. Supp. 730 ; Kavanagh v. Evans , (C. A. 6) 188 F. 2d 234 ; *153 Watson v. United States , (C. A. 10) 222 F.2d 689 ; Edward C.

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.

Rodgers v. Commissioner

25 T.C. 254 · United States Tax Court · Nov 18, 1955

S. 827 , this Court did not allow the deduction of the cost of sending the taxpayer’s children to boarding school so as to prevent the recurrence of cancer in the mother and to allow the mother to regain her voice. … Cohan v. Commissioner, 39 F. 2d 540 . In our opinion, these amounts and the additional sum expended for transportation in 1947 2 may be properly deducted as medical expenses. L. Keever Stringham, supra.

Tiffany Lashun Sanders

United States Tax Court · Nov 2, 2023

Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  4 Almost a century ago, Congress created our predecessor, the Board of Tax Appeals (BTA), as a prepayment forum for taxpayers. … It did so in the light of the conspicuous jurisdictional dismissals of untimely petitions by the Board of Tax Appeals. See Hallmark, 159 T.C. at 148–53.

Stern Bros. & Co. v. Commissioner

16 T.C. 295 · United States Tax Court · Feb 8, 1951

O’Leary, an employee of petitioner, on the board of directors of Cook Paint. … In Aluminum Castings Co. v.

National Auto. Dealers Assn. v. Commissioner

2 T.C.M. 291 · United States Tax Court · Jun 17, 1943

The chairman of the Board considered that it would be profitable. … In Crooks v.

Inland Asphalt Co. v. Commissioner

44 T.C.M. 765 · United States Tax Court · Aug 9, 1982

Carroll and Tiede together composed two-thirds of Inland Asphalt's board of directors. ↩ 4. As of November 21, 1975, Inland Asphalt's board of directors was composed of Carroll, Etter, Hedlund, and Robert M. Brown. … (See Sachs v.

Lehigh Metals Co. v. Commissioner

6 T.C. 313 · United States Tax Court · Feb 28, 1946

Muskegon Motor Specialties Co. v. Commissioner , 134 Fed. (2d) 904 ; Commissioner v. Bankers Farm Mortgage Co ., 145 Fed. (2d) 772 . … See Nelson Co. v. Helvering (1935), 296 U.S. 374 ↩ . 10.

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).

Knuckles v. Commissioner

23 T.C.M. 182 · United States Tax Court · Feb 12, 1964

Knuckles v. Commissioner. Knuckles v. Commissioner Docket No. 4139-62. United States Tax Court T.C. Memo 1964-33 ; 1964 Tax Ct. Memo LEXIS 303 ; 23 T.C.M. (CCH) 182 ; T.C.M. (RIA) 64033 ; February 12, 1964 Joseph L. … would, in the board's opinion, endanger the continued existence of Perpetual.

Toussaint v. Commissioner

47 T.C.M. 913 · United States Tax Court · Jan 11, 1984

See Green v. Commissioner, T.C. Memo. 1981-577 ; Langlois v. Commissioner, T.C. Memo. 1955-56 . … See Green v. Commissioner, supra.

Charles L. Huisking & Co. v. Commissioner

4 T.C. 595 · United States Tax Court · Jan 17, 1945

Jewel Tea Co. v. United States, 90 Fed. (2d) 451, 452. … This alone is sufficient to distinguish the instant case from Commissioner v. O. P. P. Holding Corporation, 76 Fed. (2d) 11, affirming 30 B. T. A. 337, and Commissioner v.

Evans v. Commissioner

40 T.C.M. 260 · United States Tax Court · Apr 24, 1980

EVANS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Evans v. Commissioner Docket No. 2623-78. United States Tax Court T.C. Memo 1980-142 ; 1980 Tax Ct. Memo LEXIS 445 ; 40 T.C.M. (CCH) 260 ; T.C.M. … To determine the nature of the claim settled, the focal point is the intention *455 of the payor, Knuckles v. Commissioner , 349 F.2d 610 (10th Cir. 1965) , Agar v. Commissioner , 290 F.2d 283 (2d Cir. 1961) .