Case law

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

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 .

Auburn Packing Co. v. Commissioner

60 T.C. 794 · United States Tax Court · Aug 27, 1973

United States v. Catto, supra at 114 . … Brown v. Helvering, 291 U.S. 193, 204-205 (1934). In Sam W.

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.

Ginsberg v. Commissioner

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

In Peets v. … In Commissioner v.

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.

Mollet v. Commissioner

82 T.C. 618 · United States Tax Court · Apr 18, 1984

Maxfield v. Commissioner, 153 F.2d 325, 326 (C.A. 9). See also Weinroth v. Commissioner, 74 T.C. 430, 435 (1980); Berger v. … Brown v. Commissioner, 78 T.C. 215 (1982); McCormick v. Commissioner, 55 T.C. 138 (1970).

Simmons v. Commissioner

4 T.C. 478 · United States Tax Court · Dec 15, 1944

Simmons, Petitioner, v. Commissioner of Internal Revenue, Respondent Simmons v. Commissioner Docket No. 1891 United States Tax Court 4 T.C. 478 ; 1944 U.S. Tax Ct. … The problem is not unlike that presented to the Court of Claims in Birdsboro Steel Foundry & Machine Co. v. United States , 3 Fed. Supp. 640 .

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.

Austin Transit, Inc. v. Commissioner

20 T.C. 849 · United States Tax Court · Jul 23, 1953

A. 721; Schumacher Wall Board Corporation, 33 B. T. A. 1211, affd. 93 F. 2d 79 . … C. 1080 , affd. 176 F. 2d 646 ; Survaunt v. Commissioner, 162 F. 2d 753 .

Allen v. Commissioner

12 T.C.M. 994 · United States Tax Court · Aug 31, 1953

Allen v. Commissioner. Allen v. Commissioner Docket No. 39723. United States Tax Court 1953 Tax Ct. Memo LEXIS 122 ; 12 T.C.M. (CCH) 994 ; T.C.M. … Restatement, Contracts, Sec. 421 , Krause v. Swanson, 141 Neb. 256 , 3 N.W. (2d) 407 ; Fender v. McCain, 144 Neb. 58 , 12 N.W. (2d) 541 .

Hill v. Commissioner

21 T.C.M. 1273 · United States Tax Court · Oct 9, 1962

Alvin Hill and Lula Hill v. Commissioner. Hill v. Commissioner Docket No. 90565. United States Tax Court T.C. Memo 1962-239 ; 1962 Tax Ct. Memo LEXIS 70 ; 21 T.C.M. (CCH) 1273 ; T.C.M. … On December 30, 1957, the board of directors of Hill Lines authorized the payment of a dividend.

Moore Meat Mkt. v. Commissioner

2 T.C.M. 80 · United States Tax Court · Mar 4, 1943

Moore Meat Market v. Commissioner. Moore Meat Mkt. v. Commissioner Docket No. P.T. 397. United States Tax Court 1943 Tax Ct. Memo LEXIS 419 ; 2 T.C.M. (CCH) 80 ; March 4, 1943 *419 George D. Wilson, Esq., and Rolland O. … Hearing had been held at Enid, Oklahoma, on October 20 and 21, 1942, before a member of the Board; but no findings of fact had been recommended to the Board or made by it.

Roccaforte v. Commissioner

77 T.C. 263 · United States Tax Court · Aug 10, 1981

In the recent case of Jones v. … In Bolger v.