Case law

Pulpit Resource v. Commissioner

70 T.C. 594 · United States Tax Court · Jul 31, 1978

The Franchise Tax Board for the State of California exempted Pulpit Resource from State franchise or income tax on April 22, 1976. … Group, Inc. v. Commissioner, supra, and American Institute for Economic Research v.

Estate of Goldsborough v. Commissioner

70 T.C. 1077 · United States Tax Court · Sep 27, 1978

In Harvey v. … Code art. 21, sec. 1 (1939); see Nickel v. Brown, 75 Md. 172,186 (1892).

Ashby v. Commissioner

37 T.C. 92 · United States Tax Court · Oct 26, 1961

Snell v. Commissioner, 97 F. 2d 891 , affirming a Memorandum Opinion of the Board of Tax Appeals. He devoted whatever time was necessary to carry on the business. Solly K. … Such an assignment has been held to be a “sale,” Ellis v. Peck, 45 Iowa 112 , and the as signee a “purchaser,” Light v. West, 42 Iowa 138 .

Rouse v. Commissioner

39 T.C. 70 · United States Tax Court · Oct 10, 1962

Rouse, Petitioner, v. Commissioner of Internal Revenue, Respondent Rouse v. Commissioner Docket No. 83294 United States Tax Court 39 T.C. 70 ; 1962 U.S. Tax Ct. … See Massey Motors v. United States, supra at 96.

Benny v. Commissioner

25 T.C. 197 · United States Tax Court · Oct 31, 1955

The record in this case contains the depositions of Paley, CBS’s board chairman; Trammell, the president of NBC; Lew Wasserman, the president of MCA, petitioner’s agent; George W. … The respondent argues that the question presented here is the same as in Beals’ Estate v. Commissioner, 82 F. 2d 268 (C. A. 2, 1936); and Particelli v. Commissioner, 212 F. 2d 498 (C. A. 9, 1954).

Stanley v. Commissioner

78 T.C. 423 · United States Tax Court · Mar 17, 1982

The General Dentistry Residency Program was a clinically oriented, 2-year formal training program for military dentists designed to prepare the participants for board certification in general dentistry. … See Carroll v. Commissioner, 51 T.C. 213, 218 (1968), affd. 418 F.2d 91 (7th Cir. 1969).

G-5 Inv. P'ship v. Comm'r

128 T.C. 186 · United States Tax Court · May 30, 2007

Brown, for petitioners. William F. Castor , for respondent. Haines, Harry A. HARRY A. … Sec. 6214(b) ; Hill v. Commissioner, 95 T.C. 437 , 445-446 (1990) ; *27 Calumet Indus., Inc. v.

Mill Supplies Corp. v. Commissioner

6 T.C.M. 1225 · United States Tax Court · Nov 19, 1947

Mill Supplies Corporation v. Commissioner. Mill Supplies Corp. v. Commissioner Docket No. 10479. United States Tax Court 1947 Tax Ct. Memo LEXIS 33 ; 6 T.C.M. (CCH) 1225 ; T.C.M. … Salaries were paid by the petitioner during the taxable years, pursuant to action of its board of directors, in substance as follows On February 7, 1941, Pfeifer and Elsesser being the directors present, the board voted a

Owensby & Kritikos, Inc. v. Commissioner

50 T.C.M. 29 · United States Tax Court · Jun 3, 1985

McDermott and Brown & Root. At the end of the 1979 calendar year, O&K had a total of 81 employees--40 visual inspectors, 30 nondestructive testing personnel, and 11 office personnel. … Co. v.

R. H. Oswald Co., Inc. v. Commissioner

8 T.C.M. 964 · United States Tax Court · Oct 25, 1949

Oswald Company, Inc. v. Commissioner. R. H. Oswald Co., Inc. v. Commissioner Docket No. 19641. United States Tax Court 1949 Tax Ct. Memo LEXIS 44 ; 8 T.C.M. (CCH) 964 ; T.C.M. … The minutes of the meeting of the board of directors of August 6, 1941 state: "RESOLVED, that by unanimous consent of the Board of Directors the salary *47 of R. H.

Estate of Worcester v. Commissioner

1 T.C.M. 527 · United States Tax Court · Feb 3, 1943

Worcester, Deceased, The Central Trust Company, Executor, v. Commissioner. Estate of Worcester v. Commissioner Docket No. 108989. United States Tax Court 1943 Tax Ct. Memo LEXIS 472 ; 1 T.C.M. (CCH) 527 ; T.C.M. … In the Hughes case the Board of Tax Appeals held that as a consequence of the holding of the Supreme Court in , May v. Heiner could no longer be followed and that , being deprived of the support of May v.

Norwest Corp. v. Comm'r

111 T.C. 105 · United States Tax Court · Aug 10, 1998

Co. v. … The Board of Tax Appeals (the Board) held that the cost of drilling one well only was an additional cost of the lots and “a proper charge against the sale price of the lots sold” because the taxpayer was “bound to drill but

Nuss v. Commissioner

48 T.C.M. 1221 · United States Tax Court · Sep 25, 1984

Prior to her marriageto petitioner, Clare was married to Michael Brown (hereinafter Brown) and they had two children, Traci and Michael. Clare and Brown were divorced in Oklahoma on November 7, 1975. … Welch v.

Engelhardt v. Commissioner

58 T.C. 641 · United States Tax Court · Jul 18, 1972

Cox v. Commissioner, 176 F. 2d 226 (C.A. 3, 1949); Lerner v. Commissioner, 195 F. 2d 296, 298 (C.A. 2, 1952); MacFadden v. Commissioner, 250 F. 2d 545 (C.A. 3, 1957), certiorari denied 356 U.S. 968 (1958); Bardwell v. … Maryland Casualty Co. v. United States, 251 U.S. 342, 340 (1920); Commissioner v. South Texas Co., 333 U.S. 496 (1948).

Rose v. Comm'r

48 T.C.M. 1331 · United States Tax Court · Oct 4, 1984

Davis v. … Memo. 1984-400 ; Hodges v. Commissioner, T.C. Memo. 1984-385 ; Johnson v. Commissioner, T.C. Memo. 1984-164 ; Leslie v. Commissioner, T.C. Memo. 1984-61 . See also the cases cited in footnote 9 of Davis v.

William C. Atwater & Co. v. Commissioner

10 T.C. 218 · United States Tax Court · Feb 4, 1948

Lucas v. Ox *248 Fibre Brush Co ., 281 U.S. 115 ; Hudson Motor Car Co. v. United States , 3 Fed. … In Athens Roller Mills, Inc. v.

Apex Electrical Mfg. Co. v. Commissioner

16 T.C. 1171 · United States Tax Court · May 29, 1951

The Apex Electrical Manufacturing Company, an Ohio Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Apex Electrical Mfg. Co. v. … Spring City Foundry Co. v. Commissioner , 292 U.S. 184 ; United States Cartridge Co. v. United States , 284 U.S. 511 ; Lichtenberger-Ferguson Co. v. Welch (C. A. 9), 54 F. 2d 570 ; Luckenbach Steamship Co ., 9 T.

Quaker Oats Co. v. Commissioner

28 T.C. 626 · United States Tax Court · Jun 11, 1957

The Quaker Oats Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Quaker Oats Co. v. Commissioner Docket No. 48679 United States Tax Court 28 T.C. 626 ; 1957 U.S. Tax Ct. … The board of directors requested and authorized the executive committee of petitioner to proceed with the preparation of a pension plan.

Indialantic, Inc. v. Commissioner

12 T.C.M. 880 · United States Tax Court · Jul 31, 1953

Indialantic, Inc. v. Commissioner. Indialantic, Inc. v. Commissioner Docket No. 37274. United States Tax Court 1953 Tax Ct. Memo LEXIS 163 ; 12 T.C.M. (CCH) 880 ; T.C.M. (RIA) 53265 ; July 31, 1953 *163 B. … Hoffman Radio Corporation v. Commissioner, 177 Fed. (2d) 264 .

Kelley v. Commissioner

66 T.C.M. 1132 · United States Tax Court · Oct 27, 1993

Smith v. Commissioner , docket No. 10171-86; Benatovich v. … Part of the Brown Minter property was also subleased to Buffalo Coal (1980).