Case law

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  • T. v. D. Co. v. Commissioner

    27 T.C. 879 · United States Tax Court · Feb 28, 1957

    V. D. Co., is an Ohio corporation having its principal office in Cincinnati, Ohio. It was originally known as the DuBois Co. … They were elected Enterprise’s officers and directors, and, in addition, two directors were nominated and elected to Enterprise’s board of directors by the Bank of America.

    Cited 20 timesPublished
  • Rialto Mining Corp. v. Commissioner

    1 T.C.M. 303 · United States Tax Court · Dec 26, 1942

    Rialto Mining Corporation v. Commissioner. Rialto Mining Corp. v. Commissioner Docket No. 109365. United States Tax Court 1942 Tax Ct. Memo LEXIS 9 ; 1 T.C.M. (CCH) 303 ; T.C.M. (RIA) 42676 ; 12/26/1942 *9 Tom F. … Its right to deduct depletion on the percentage basis for 1933 was sustained by Board. 8.

    Cited 0 timesUnpublished
  • Sims v. Commissioner

    30 T.C.M. 1295 · United States Tax Court · Nov 29, 1971

    Sims, Jr. v. Commissioner. Sims v. Commissioner Docket No. 4446-69. United States Tax Court T.C. Memo 1971-303 ; 1971 Tax Ct. Memo LEXIS 33 ; 30 T.C.M. (CCH) 1295 ; T.C.M. … . *33 Business v. nonbusiness bad debt: Loan v. participation in joint venture: Fact finding. - Johns asked Browning and Cohen to obtain a loan for him of $35,000.

    Cited 0 timesUnpublished
  • Girard Trust Corn Exchange Bank v. Commissioner

    22 T.C. 1343 · United States Tax Court · Sep 30, 1954

    Snell v. Commissioner , 97 Fed. (2d) 891 ; Ehrman v. … . * * * To the same effect is Brown v. Commissioner , (C.

    Cited 2 timesPublished
  • Montgomery Co. v. Commissioner

    22 T.C.M. 479 · United States Tax Court · Apr 10, 1963

    Bernard Brown, *241 Esq., for the petitioner. Arthur Clark, Jr., Esq., for the respondent. … Providence Journal Co. v. Broderick, supra.

    Cited 0 timesUnpublished
  • William P. Wells & Ruth E. Wells

    United States Tax Court · Jun 10, 2026

    Wells and Bill Payne, a former FCA board member, each owned a 50% interest in Chamberlain. … CHA’s board of directors for the tax period ending May 31, 2016, consisted of Messrs. Bowen, Montgomery, and Wells. CHA’s board of directors for the tax period ending May 31, 2017, included Messrs.

    Cited 0 timesUnpublished
  • Thomas v. Comm'r

    105 T.C.M. 1403 · United States Tax Court · Feb 26, 2013

    BROWNE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22909-10. Filed February 26, 2013. Michael L. … Browne, is not liable for the income tax liabilities or penalties because of the application of section 6015.

    Cited 1 timesUnpublished
  • EPCO, Inc. v. Commissioner

    69 T.C.M. 2829 · United States Tax Court · Jun 12, 1995

    In 1950, the Supreme Court, in Brown Shoe v. … We noted that the Supreme Court in Brown Shoe v.

    Cited 0 timesUnpublished
  • Corri A. Feige

    United States Tax Court · Aug 18, 2025

    See Walquist v. Commissioner, 152 T.C. 61, 67 (2019); see also Weimerskirch v. … See § 7491(c); Wheeler v.

    Cited 0 timesUnpublished
  • Elm Street Realty Trust v. Commissioner

    76 T.C. 803 · United States Tax Court · May 18, 1981

    In Morrissey v. … In Morrissey v.

    Cited 7 timesPublished
  • Pomeroy Coop. Grain Co. v. Commissioner

    31 T.C. 674 · United States Tax Court · Dec 31, 1958

    Burnet v. Harmel, 287 U. S. 103, 110 . … A. 315, 326, affd. 56 F. 2d 90 ; and Farmers Cooperative Co. v. Birmingham, (N. D. Iowa) 86 F. Supp. 201 .

    Reversed on other grounds by Pomeroy Cooperative Grain Company v. Commissioner of Internal Revenue, 288 F.2d 326 (1961)Cited 27 timesPublished
  • Reverend & Mrs. Harold L. DuRossette v. Commissioner

    11 T.C.M. 413 · United States Tax Court · Apr 23, 1952

    DuRossette v. Commissioner. Reverend & Mrs. Harold L. DuRossette v. Commissioner Docket No. 28556. United States Tax Court 1952 Tax Ct. Memo LEXIS 246 ; 11 T.C.M. (CCH) 413 ; T.C.M. … Cohan v. Commissioner, 39 Fed. (2d) 540 .

    Cited 0 timesUnpublished
  • Swiss Colony, Inc. v. Commissioner

    52 T.C. 25 · United States Tax Court · Apr 8, 1969

    Swiss Colony, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent Swiss Colony, Inc. v. Commissioner Docket No. 2918-66 United States Tax Court 52 T.C. 25 ; 1969 U.S. Tax Ct. … As the Court of Appeals stated in Colonial Fabrics v.

    Cited 16 timesPublished
  • Katz v. Commissioner

    1998 U.S. Tax Ct. LEXIS 61 · United States Tax Court · May 14, 1998

    SCOTT WILLIAM KATZ, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Katz v. Commissioner Docket No. 21359-96 United States Tax Court 1998 U.S. Tax Ct. LEXIS 61 ; May 14, 1998 , Entered *61 KENNETH A. … BROWN Chief Counsel Internal Revenue Service Date: may 6, 1998 Date: 5-7-98

    Cited 1 timesUnpublished
  • Cimarron Trust Estate v. Commissioner

    59 T.C. 195 · United States Tax Court · Oct 31, 1972

    Paragraph (f) was upheld in United States v. … In Leo Sheep Co. v. Schuster, 234 F. Supp. 761 (D.

    Cited 15 timesPublished
  • Adams v. Commissioner

    1 T.C.M. 929 · United States Tax Court · Apr 21, 1943

    Adams v. Commissioner. Adams v. Commissioner Docket No. 112228. United States Tax Court 1943 Tax Ct. Memo LEXIS 353 ; 1 T.C.M. (CCH) 929 ; T.C.M. (RIA) 43183 ; April 21, 1943 *353 Raymond C. … Here, as we have said, the proceeding before the Board related not to an investment item of income or expense but directly to the taxpayer's business income. The determination is reversed.

    Cited 0 timesUnpublished
  • Smith v. Commissioner

    42 T.C.M. 431 · United States Tax Court · Jul 20, 1981

    Soon thereafter, at a banquet for the Museum membership, attended by members of the Board of Directors, petitioner handed the original copyright certificate to W.C. … Rogers v. United States , 340 U.S. 367 , 374 (1951) ; Brown v. Walker , 161 U.S. 591 , 599-600 (1896) ; Wilkinson v. Commissioner , 71 T.C. 633 , 638 (1979) ; Roberts v. Commissioner , 62 T.C. 834 , 838 (1974) .

    Cited 1 timesUnpublished
  • Topeka Insurors v. Commissioner

    12 T.C. 428 · United States Tax Court · Mar 24, 1949

    Commissioner v. Brouillard (C. C. A., 10th Cir.), 70 Fed. (2d) 154. … There was nothing having the character of an investment such as the apartment houses considered in Helvering v. Coleman-Gilbert Associates, 296 U. S. 369 , or the oil leases in Helvering v. Combs, 296 U. S. 365 .

    Cited 0 timesPublished
  • Lantz Bros. v. Commissioner

    5 T.C. 896 · United States Tax Court · Oct 12, 1945

    Sanford v. Sanford, 286 Fed. 777 . … A. 1245, wherein the Board commented upon a similar provision in the Revenue Act of 1918 in the following language: In the enactment of section 218 (a) Congress ignored for taxing purposes the existence of the partnership

    Cited 3 timesPublished
  • Compaq Computer Corp. v. Commissioner

    78 T.C.M. 20 · United States Tax Court · Jul 2, 1999

    . & Subs. v. … v. Commissioner, 92 T.C. 525, 582 (1989), affd. 933 F.2d 1084 (2d - 28 - Cir. 1991); G.D. Searle & Co. v. Commissioner, 88 T.C. 252, 358 (1987); Paccar, Inc. v.

    Cited 1 timesUnpublished

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