Case law

KTA-Tator, Inc. v. Commissioner

108 T.C. 100 · United States Tax Court · Mar 11, 1997

Petitioner was authorized by its board of directors to loan funds to the Tators for construction, the purchase of land, and other business purposes. … Woolworth Co. v. Commissioner, 54 T.C. 1233, 1265-1266 (1970).

Chick v. Commissioner

7 T.C. 1414 · United States Tax Court · Dec 31, 1946

See Frederich v. Commissioner, 145 Fed. (2d) 796. … On the basis of the stipulated facts, see Iowa Bridge Co. v.

Modesto Dry Yard, Inc. v. Commissioner

14 T.C. 374 · United States Tax Court · Mar 9, 1950

App. 742 ; Turner, Kuhn & Fraser, Inc. v. Jones, 215 Pac. 1033 ; 61 Cal. App. 732 ; Walti v. Gaba, 116 Pac. 963 ; 160 Cal. 324 ; Blackwood v. Cutting Packing Co., 18 Pac. 248 ; 76 Cal. 212 ; Haas Bros. v. … Brown Lumber Co., 9 B. T. A. 719; affd., 35 Fed. (2d) 880; Barde Steel Products Corporation, 14 B. T. A. 209; affd., 40 Fed. (2d) 412; certiorari denied, 282 U. S. 853 ; Jagerson Fuel Co., 24 B. T.

Lime Cola Co. v. Commissioner

22 T.C. 593 · United States Tax Court · Jun 17, 1954

S. 322 ; Commissioner v. Jacobson, 336 U. S. 28 ; or a nontaxable reduction in the purchase price of the flavoring, see Hirsch v. Commissioner, (C. A. 7) 115 F. 2d 656 . … (a) Burden of Pkoof. — In procedings before the Board the burden of proof shall be upon the Commissioner to show that a petitioner is liable as a transferee of property of a taxpayer, but not to show that the taxpayer was

Soreng v. Commissioner

4 T.C. 870 · United States Tax Court · Feb 28, 1945

Soreng, Petitioner, v. Commissioner of Internal Revenue, Respondent. Mary Soreng, Petitioner, v. Commissioner of Internal Revenue, Respondent Soreng v. … Royal Manufacturing Co. v. Commissioner , *877 139 Fed. (2d) 958 ; Pacific Grape Products Co ., 42 B. T. A. 914 .

Wallerstein v. Commissioner

2 T.C. 542 · United States Tax Court · Aug 10, 1943

Leo Wallerstein, Petitioner, v. Commissioner of Internal Revenue, Respondent Wallerstein v. Commissioner Docket No. 107761 United States Tax Court 2 T.C. 542 ; 1943 U.S. Tax Ct. … The certificate of incorporation originally provided, and as amended still provides, that the first preferred stock (about which this controversy centers) or any part thereof, might be redeemed at the option of the board

Hibler v. Commissioner

46 T.C. 663 · United States Tax Court · Aug 23, 1966

Cases like Thomas v. Perkins, 301 U.S. 655 (1937), and United States v. … See Commissioner v. Brown, 380 U.S. 563, 575-576 (1965), and Anderson v. Helvering, 310 U.S. 401, 413 (1940).

Johnson v. Commissioner

25 T.C. 123 · United States Tax Court · Oct 27, 1955

Although a distinction of this nature was accepted in Keasbey & Mattison Co. v. United States, (C. … See Herberger v. Commissioner, (C. A. 9) 195 F. 2d 293, 295 , certiorari denied 344 U. S. 820 .

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 .

Dreifus v. Commissioner

36 T.C.M. 368 · United States Tax Court · Mar 28, 1977

DREIFUS, DECEASED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Dreifus v. Commissioner Docket No. 3365-75. United States Tax Court T.C. Memo 1977-83 ; 1977 Tax Ct. Memo LEXIS 358 ; 36 T.C.M. … OPINION Petitioner sent his two sons, both of whom suffered from adjustment related difficulties, to a boarding school during 1972.

Harris v. Commissioner

4 T.C.M. 818 · United States Tax Court · Jul 31, 1945

Ben Harris and Rhea Harris v. Commissioner. Harris v. Commissioner Docket No. 5953. United States Tax Court 1945 Tax Ct. Memo LEXIS 105 ; 4 T.C.M. (CCH) 818 ; T.C.M. (RIA) 45265 ; July 31, 1945 Meyer A. … There are about 150 saloons in Mahoning County and the petitioner was successful in getting the punch boards installed in many of them.

Gorman Lumber Sales Co. v. Commissioner

12 T.C. 1184 · United States Tax Court · Jun 30, 1949

Dixie Pine Products Co. v. Commissioner, 320 U. S. 516 . … C. 990 ; modified as to one year in Wier Long Leaf Lumber Co. v. Commissioner, 173 Fed. (2d) 549; and Rite-Way Products, Inc., 12 T. C. 475 .

Owens v. Commissioner

38 T.C.M. 333 · United States Tax Court · Mar 12, 1979

See Helvering v. Davis, 301 U.S. 619 (1937) ; and Cain v. United States, 211 F.2d 375 (5th Cir. 1954) . … As stated by Justice Black and Justice Douglas in their concurring opinion in Board of Education v.

Association of The Bar v. Commissioner

89 T.C. 599 · United States Tax Court · Sep 17, 1987

Dulles v. … See Cammarano v. United States, 358 U.S. 498, 512-513 (1959); Slee v. Commissioner, 42 F.2d 184, 185-186 (2d Cir. 1930), affg. 15 B.T.A. 710 (1929); Christian Echoes National Ministry, Inc. v.

Ginsberg v. Commissioner

35 T.C. 1148 · United States Tax Court · Mar 31, 1961

In Peets v. … In Commissioner v.

Thermal Energy Concepts v. Commissioner

66 T.C.M. 1368 · United States Tax Court · Nov 22, 1993

VICE PRESIDENT. *568 In the absence or disability of the President, the Vice Presidents, in order of their rank as fixed by the Board of Directors, or if not ranked, the Vice President designated by the Board of Directors … of the corporation, and shall have such other powers and perform such other duties as may be prescribed by the Board of Directors or the By-Laws. * * * ARTICLE VI CORPORATE CONTRACTS AND INSTRUMENTS-HOW EXECUTED The Board

Black v. Comm'r

107 T.C.M. 1147 · United States Tax Court · Feb 12, 2014

Brown v. Commissioner, 2011WL 1396936, at *4-*6. … See Atwood v. Commissioner, T.C. Memo. 1999-61; see also Brown v. Commissioner, T.C. Memo. 2011-83; McGowen v.

Estate of Hekman v. Commissioner

16 T.C.M. 304 · United States Tax Court · Apr 30, 1957

Estate of John Hekman, Deceased et al. v. Commissioner. Cornelia Hekman v. Commissioner. Estate of Hekman v. Commissioner Docket Nos. 56358, 56359. United States Tax Court T.C. Memo 1957-70 ; 1957 Tax Ct. … McClellan did this as president of United Biscuit Company and he reported it to the board of directors.

Peters v. Commissioner

21 T.C. 55 · United States Tax Court · Oct 15, 1953

Isabel Peters, Petitioner, v. Commissioner of Internal Revenue, Respondent Peters v. Commissioner Docket No. 40813 United States Tax Court 21 T.C. 55 ; 1953 U.S. Tax Ct. … Also see Ould v. Washington Hospital , 95 U.S. 303 , *57 wherein the Supreme Court cited with approval the following definition of charity used by counsel in Vidal v.

Zirker v. Commissioner

87 T.C. 970 · United States Tax Court · Oct 30, 1986

Brown, 380 U.S. 563, 570-571 (1965). … Stanley Works and Subsidiaries v. Commissioner, 87 T.C. 389 (1986); Johnson v. Commissioner, 85 T.C. 469, 482 (1985); Law v.