Case law

Hitner v. Commissioner

1 T.C.M. 596 · United States Tax Court · Feb 13, 1943

Hitner v. Commissioner. Hitner v. Commissioner Docket No. 109684. United States Tax Court 1943 Tax Ct. Memo LEXIS 448 ; 1 T.C.M. (CCH) 596 ; T.C.M. … Included in this trust was petitioner's share of the claim against the Shipping Board. Petitioner has not shown that he ever made a gift of his interest in the claim *453 against the Shipping Board.

F. S. Harmon Mfg. Co. v. Commissioner

34 T.C. 316 · United States Tax Court · May 25, 1960

Macy & Co. v. United States, 255 F. 2d 884 (C.A. 2), and Kaufmann and Baer Company, et al. v. United States, 133 Ct. Cl. 510 , 137 F. Supp. 725 . … As said in Brown v. Helvering, 291 U.S. 193 , 204: “It is not the province of the court to weigh and determine the relative merits of systems of accounting.”

Quatman v. Commissioner

54 T.C. 339 · United States Tax Court · Feb 24, 1970

The question in Gilmore v. … See Frances Carroll Brown, 30 T.C. 831 (1958). Respondent contends that if the income interests are present interests, the exclusions are nevertheless unallowable because such interests are incapable of valuation.

Glenshaw Glass Co. v. Commissioner

5 T.C.M. 864 · United States Tax Court · Oct 15, 1946

Glenshaw Glass Company, Inc., a corporation v. Commissioner. Glenshaw Glass Co. v. Commissioner Docket No. 6994. United States Tax Court 1946 Tax Ct. Memo LEXIS 58 ; 5 T.C.M. (CCH) 864 ; T.C.M. … Crescent Bed Co., Inc. v. Commissioner, 133 Fed. (2d) 424 . Petitioner also offered expert testimony on the reasonableness of the compensation paid.

Smith v. Commissioner

66 T.C. 213 · United States Tax Court · Apr 28, 1976

A case almost directly on point is Hooper Construction Co. v. … Cases cited by petitioners, such as Thompson-King-Tate, Inc. v. United States, 296 F.2d 290 (6th Cir. 1961), and E. E. Black, Ltd. v. Alsup, 211 F.2d 879 (9th Cir. 1954), are distinguishable.

Galewitz v. Commissioner

50 T.C. 104 · United States Tax Court · Apr 17, 1968

See, also, Trust of Bingham v. Commissioner, 325 U.S. 365 ; Frederick E. Rowe, 24 T.C. 382 ; and Allen v. Selig, 200 F. 2d 487 , affirming 104 F. Supp. 390 . … This case is distinguishable on its facts from Morgan, Jones Estate, 43 B.T.A. 691 , affd. 127 F. 2d 231 ; Addison v. Commissioner, 177 F. 2d 521, 523 ; and E. W. Brown, Jr., 19 T.C. 87 , affd. 215 F. 2d 697 .

Reed v. Commissioner

50 T.C. 630 · United States Tax Court · Jul 29, 1968

.); Flanagan v. Railroad Retirement Board, 332 F. 2d 301, 303 . This would seem to limit the meaning of the word “child” to the natural child of both or one of the taxpayers.

Johnson Inv. & Rental Co. v. Commissioner

70 T.C. 895 · United States Tax Court · Sep 11, 1978

In Logan Coal & Timber Assn. v. … Warren Browne, Inc. v. Commissioner, 14 T.C. 1056 , 1063 (1950); U.S. Universal Joints Co. v. Commissioner, 46 B.T.A. 111 , 115-116 (1942); Kiesau Petroleum Corp. v.

Hardtke v. Commissioner

71 T.C.M. 3220 · United States Tax Court · Jun 26, 1996

board meeting). … Lucas v. Earl, 281 U.S. 111 (1930).

Priester v. Commissioner

38 T.C. 316 · United States Tax Court · May 29, 1962

Holsey v. Commissioner, 3 Cir., 258 F. 2d 865 .° Schmitt v. … See also Stout v.

Huttig Sash & Door Co. v. Commissioner

25 T.C. 550 · United States Tax Court · Dec 19, 1955

Huttig Sash & Door Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Huttig Sash & Door Co. v. Commissioner Docket No. 11795 United States Tax Court 25 T.C. 550 ; 1955 U.S. Tax Ct. … board, roof insulation, and cold storage insulation board, all of which were sold under the trade name of Insulite.

Roth Steel Tube Co. v. Commissioner

68 T.C. 213 · United States Tax Court · May 23, 1977

Windhorst v. Brandt, 18 Ohio App. 59 (1923). … v.

Foglesong v. Commissioner

35 T.C.M. 1309 · United States Tax Court · Sep 20, 1976

FOGLESONG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent FRED H. FOGLESONG CO., INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Foglesong v. Commissioner Docket Nos. 4725-73, 4726-73. … Inc. v.

Buccola v. Commissioner

54 T.C. 1599 · United States Tax Court · Aug 6, 1970

It is this provision to which Commissioner v. … Commissioner v.

D'Arcy-MacManus & Masius, Inc. v. Commissioner

63 T.C. 440 · United States Tax Court · Jan 2, 1975

See Vulcan Materials Co. v. … See also Zanesville Investment Co. v. Commissioner, 335 F. 2d 507, 514 (C.A. 6, 1964), reversing and remanding 38 T.C. 406 (1962).

Heiderich v. Commissioner

19 T.C. 382 · United States Tax Court · Dec 4, 1952

Heiderich, Petitioners, v. Commissioner of Internal Revenue, Respondent. Henry A. Ramey and T. Lucille Ramey, Petitioners, v. Commissioner of Internal Revenue, Respondent Heiderich v. … On September 30, 1943, pursuant to a resolution of the board of directors, the corporation was liquidated and dissolved and all of its assets (other than the lease of the premises then occupied by the corporation) were transferred

Dyke v. Commissioner

6 T.C. 1134 · United States Tax Court · May 23, 1946

In Texon Oil & Land Co. v. United States , 115 Fed. (2d) 647 , and Big Lake Oil Co. v. … In Norman v. Wilson , 41 S.

Beaver Valley Canning Co. v. Commissioner

9 T.C.M. 1120 · United States Tax Court · Dec 13, 1950

Beaver Valley Canning Company v. Commissioner. Beaver Valley Canning Co. v. Commissioner Docket No. 22086. United States Tax Court 1950 Tax Ct. Memo LEXIS 13 ; 9 T.C.M. (CCH) 1120 ; T.C.M. … At a meeting on August 28, 1943, the Board of Directors passed a resolution providing that shareholder-customers "* * * shall be entitled to such patronage dividends as the Board of Directors of Beaver Valley Canning Company

Escobar v. Commissioner

68 T.C. 304 · United States Tax Court · May 31, 1977

The Board at page 1247 stated that it did not think this sentence of the regulation was decisive since "Irrebuttable presumptions are not favored.” … See also Marsh v. Commissioner, 68 T.C. 68 (1977).

Harvey Radio Laboratories, Inc. v. Commissioner

31 T.C.M. 333 · United States Tax Court · Apr 10, 1972

Also, the minutes of petitioner's board of directors meeting of June 16, 1966, disclose that the board not only approved the Purchase and Sale Agreement but considered an amendment to Section P-1 thereof which dealt with … Indeed, in Tobin v.