Case law

Estate of Johnston v. Commissioner

51 T.C. 290 · United States Tax Court · Nov 26, 1968

Johnston (hereinafter sometimes referred to as Johnston or petitioner) and Margaret 'V. … Tuso v. Green, 229 Pac. 329 ; Brown v. Roberts, 9 P. 2d 517 ; Williams v. Rush, 25 P. 2d 888 . The Commissioner contends this is not enough to constitute a “purchase” of the land within the time limits of section 1033.

Neel v. Commissioner

10 T.C.M. 323 · United States Tax Court · Mar 30, 1951

Neel v. Commissioner. Roland H. Neel and Evelyn J. Neel v. Commissioner. Joseph N. Neel and Blanche H. Neel v. Commissioner. Jos. N. Neel Co. v. Commissioner. Neel v. Commissioner Docket Nos. 23734, 23735, 23736, 24927. … V. Sheridan A. N. Hummel W. M.

State Police Ass'n v. Commissioner

1996 U.S. Tax Ct. LEXIS 51 · United States Tax Court · Nov 6, 1996

STATE POLICE ASSOCIATION, OF MASSACHUSETTS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent State Police Ass'n v. Commissioner Docket No. 15443-93 United States Tax Court 1996 U.S. Tax Ct. … BROWN, Chief Counsel LAURENCE D.

Fedders Corp. v. Commissioner

39 T.C.M. 1 · United States Tax Court · Sep 4, 1979

Some members of Borg-Warner's board of directors had always had reservations about the Norge Division. … Many of the Norge distributors had strong brown goods lines, Zenith or Motorola, which associations strengthened the distributorships.

Ford v. Commissioner

56 T.C. 1300 · United States Tax Court · Sep 15, 1971

In Furrier v. … See Deputy v. DuPont, 308 U.S. 488, 495 (1940). Justice Cardozo, in Welch v.

Olive v. Commissioner

139 T.C. 19 · United States Tax Court · Aug 2, 2012

MARTIN OLIVE, PETITIONER v. … COMMISSIONER 27 rolling papers, zip bags, vaporizer bags, lighters, brown paper bags, containers and storage

Speer v. Commissioner

72 T.C.M. 125 · United States Tax Court · Jul 16, 1996

Paxson sat on the board of directors of CHSN. … See Brown Printing Co. v. Commissioner, 255 F.2d at 440.

Stinson Sch. of Aviation, Inc. v. Commissioner

4 T.C.M. 1028 · United States Tax Court · Nov 21, 1945

Stinson School of Aviation, Inc. v. Commissioner. Stinson Sch. of Aviation, Inc. v. Commissioner Docket No. 6105. United States Tax Court 1945 Tax Ct. Memo LEXIS 35 ; 4 T.C.M. (CCH) 1028 ; T.C.M. … About 1934 he was employed part time by the Board of Education in New York City as an instructor in aviation in the schools of New York.

Borax v. Commissioner

40 T.C. 1001 · United States Tax Court · Sep 20, 1963

Holt v. Commissioner, supra; Feinberg v. … Brown, 7 T.C. 715 (1946); Estate of Daniel Buckley, 37 T.C. 664 (1962); Smith v. Commissioner, 168 F. 2d 446 (C.A. 2, 1948), affirming a Memorandum Opinion of this Court; Daine v.

Aspro, Inc.

United States Tax Court · Jan 21, 2021

V. Management Fees Petitioner Paid to Shareholders Petitioner’s board of directors had seven members in tax year 2012: Mr. Dakovich, Mr. Jackson, Mr. Rost, Mr. … Instead, petitioner’s board of directors would approve the management fees to be paid to the shareholders at a board meeting later in the tax year, when the board had a better idea how the company was going to perform

Scottish American Inv. Co. v. Commissioner

12 T.C. 49 · United States Tax Court · Jan 27, 1949

McCoach v. Mine Hill & Schuylkill Haven Railway Co., 228 U. S. 295 . … Jones Trust v. Commissioner, 4 Cir., 132 F. 2d 914, 917 .”

Bakewell v. Commissioner

23 T.C. 803 · United States Tax Court · Jan 31, 1955

Paul Bakewell, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent Bakewell v. Commissioner Docket No. 47853 United States Tax Court 23 T.C. 803 ; 1955 U.S. Tax Ct. … However, in Sparkman v.

Okonite Co. v. Commissioner

4 T.C. 618 · United States Tax Court · Jan 29, 1945

The dividends were payable only out of earnings when and if declared by the board of directors and were not payable out of funds at all events, a provision characteristic of interest. … May Hosiery Mills, Inc. v. Commissioner, 123 Fed. (2d) 858; Commissioner v. Meridian & Thirteenth Realty Co., 132 Fed. (2d) 182.

Mottahedeh v. Comm'r

108 T.C.M. 654 · United States Tax Court · Dec 29, 2014

In Weimerskirch v. … In Palmer v.

Pennroad Corp. v. Commissioner

29 T.C. 914 · United States Tax Court · Feb 20, 1958

The Pennroad Corporation and Affiliated Companies, Petitioner, v. Commissioner of Internal Revenue, Respondent Pennroad Corp. v. Commissioner Docket Nos. 58979, 64889 United States Tax Court 29 T.C. 914 ; 1958 U.S. … Cohn v. Commissioner , 226 F. 2d 22 , affirming 21 T. C. 90 ; and Greene v. Commissioner , 141 F. 2d 645 , affirming a Memorandum Opinion of this Court dated October 31, 1942.

Vern Realty, Inc. v. Commissioner

58 T.C. 1005 · United States Tax Court · Sep 21, 1972

Petitioner relies upon such cases as Fetzer Refrigerator Co. v. … Byrne, supra; Commissioner v. Scatena, supra; and Minal E.

Chas. Olson & Sons v. Commissioner

1 T.C.M. 78 · United States Tax Court · Nov 10, 1942

Olson & Sons, Incorporated v. Commissioner. Chas. Olson & Sons v. Commissioner Docket No. 109980. United States Tax Court 1942 Tax Ct. Memo LEXIS 92 ; 1 T.C.M. (CCH) 78 ; T.C.M. … Nevertheless, on all the facts it was held that the ruling of the Board of Tax Appeals that the interest was deductible was correct.

Turner v. Commissioner

23 T.C.M. 1186 · United States Tax Court · Jul 17, 1964

Mary Ellis Turner v. Commissioner. Turner v. Commissioner Docket No. 92011. United States Tax Court T.C. Memo 1964-195 ; 1964 Tax Ct. Memo LEXIS 141 ; 23 T.C.M. (CCH) 1186 ; T.C.M. … See also Morton v.

Illinois Grain Corp. v. Commissioner

87 T.C. 435 · United States Tax Court · Aug 18, 1986

In Linnton Plywood Association v. … In Farm Service Cooperative v.

McCall v. Commissioner

37 T.C. 674 · United States Tax Court · Jan 12, 1962

Parsons v. … Brown, 22 T.C. 58 (1954); and James Ruston, 19 T.C. 284 (1952).”