Case law

Herman W. & Gay K. Fletcher v. Commissioner

10 T.C.M. 793 · United States Tax Court · Aug 28, 1951

Fletcher v. Commissioner. Herman W. & Gay K. Fletcher v. Commissioner Docket No. 29870. United States Tax Court 1951 Tax Ct. Memo LEXIS 123 ; 10 T.C.M. (CCH) 793 ; T.C.M. (RIA) 51264 ; August 28, 1951 John J. … Blair v. Commissioner, 300 U.S. 5 ; Beulah Eaton McAllister v.

Holland v. Commissioner

51 T.C.M. 164 · United States Tax Court · Dec 26, 1985

See Flowers v. Commissioner, 80 T.C. 914 , 931 (1983) ; Pike v. … Griffith v. Commissioner, 749 F.2d 11 (6th Cir. 1984) , affg. T.C. Memo. 1983-278 ; Benedict v. Commissioner, 82 T.C. 573 (1984) ; Yoakum v. Commissioner, 82 T.C. 128 (1984) ; Thompson v.

Subscription Television, Inc. v. Commissioner

33 T.C.M. 538 · United States Tax Court · Apr 30, 1974

SUBSCRIPTION TELEVISION, INC., SUCCESSOR BY MERGER TO JOHN BLUE COMPANY, INC., ET AL., 1 Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Subscription Television, Inc. v. … United States v. Anderson, 269 U.S. 422 (1926) , and Chesapeake Corporation of Virginia, supra. Accordingly, where a liability is contingent and not fixed, it cannot be deducted as accrued.

Dees v. Comm'r

113 T.C.M. 3905 · United States Tax Court · Feb 2, 2017

Olsen v. Helvering, 88 F.2d 650, 651 (2d Cir. 1937), aff’g a Memorandum Opinion of the Board of Tax Appeals. … Olsen v. Helvering, 88 F.2d 650, 651 (2d Cir. 1937), aff’g a Memorandum Opinion of the Board of Tax Appeals.

Williamson v. Commissioner

27 T.C. 647 · United States Tax Court · Jan 17, 1957

West Texas Refining & Development Co. v. Commissioner, 68 F. 2d 77 (C. A. 10, 1933); Halliburton v. Commissioner, 78 F. 2d 265 (C. A. 9, 1935); Commissioner v. Schumacher Wall Board Corporation, 93 F. 2d 79 (C. … Decisions will ~be entered v/nder Rule 50.

Seagate Technology v. Commissioner

102 T.C. 149 · United States Tax Court · Feb 8, 1994

See Eli Lilly & Co. v. Commissioner, 856 F.2d at 860 ; Sundstrand Corp. v. Commissioner, supra at 354. … See Yamaha Motor Corp., U.S.A. v. Commissioner, T.C. Memo. 1992-110 ; Forte v. Commissioner, T.C. Memo. 1991—36; National Oil Co. v. Commissioner, T.C. Memo. 1986-596 ; cf. McSpadden v.

Driggs v. Commissioner

87 T.C. 759 · United States Tax Court · Sep 30, 1986

Co. v. United States, 205 Ct. Cl. 597 , 505 F.2d 1266 (1974); Estate of Baron v. Commissioner, 83 T.C. 542, 549-550 (1984), affd. 798 F.2d 65 (2d Cir. 1986); Saviano v. … Woolworth Co. v. Commissioner, 54 T.C. 1233, 1265-1266 (1970); Miller v. Commissioner, 70 T.C. 448, 460 (1978). See also Mearkle v. Commissioner, 87 T.C. 527 (1986).

Burdorf v. Commissioner

20 T.C.M. 1621 · United States Tax Court · Nov 20, 1961

Brown, Jr., Esq., for the respondent. … Thomas v. Commissioner, 223 F. 2d 83 , at p. 86 (C.A. 6, 1955).

Professional Services v. Commissioner

79 T.C. 888 · United States Tax Court · Nov 23, 1982

The named trustees (i.e., petitioner) of these organizations could be removed only by a unanimous resolution of the board of trustees, 12 or by a court. … Resolutions of the Board of Trustees authorizing a special thing to be done shall be evidenced [sic] that such act is within its power.

United Industrial Corp. v. Commissioner

21 T.C.M. 1482 · United States Tax Court · Nov 28, 1962

United Industrial Corporation and Subsidiary Companies v. Commissioner. United Industrial Corporation v. Commissioner. United Industrial Corp. v. Commissioner Docket Nos. 86422, 86423. United States Tax Court T.C. … As a result of the stock dividend declared by the Board of Directors of petitioner on June 29, 1956, the surplus was capitalized; that is, the amount of $6.50 was transferred from the surplus account for each share issued

Salzman v. Commissioner

21 T.C. 777 · United States Tax Court · Feb 26, 1954

Joseph Salzman, Petitioner, v. Commissioner of Internal Revenue, Respondent. Harry Salzman, Petitioner, v. Commissioner of Internal Revenue, Respondent Salzman v. … Jerry Rossman Corporation v. Commissioner , 175 F. 2d 711 .

King v. Commissioner

87 T.C. 1213 · United States Tax Court · Dec 2, 1986

The CME is a domestic board of trade designated as a contract market by the Commodity Futures Trading Commission. … See Perlin v. Commissioner, 86 T.C. 388 (1986); cf. Glass v. Commissioner, 87 T.C. 1087 (1986).

Jon Dickinson & Helen Dickinson v. Commissioner

2020 T.C. Memo. 128 · United States Tax Court · Sep 3, 2020

The GCI board of directors (Board) authorized shareholders to donate GCI shares to Fidelity Investments Charitable Gift Fund (Fidelity), an organization tax exempt under section 501(c)(3), through written consent actions … The Board approved a third round of donations at a Board meeting by unanimous vote in 2015; the Board members signed the written minutes of the meeting.

Estate of Harrison v. Commissioner

115 T.C. 161 · United States Tax Court · Aug 22, 2000

H and W boarded their private aircraft in July of 1993 but never arrived at their destination. … BACKGROUND On or about July 25, 1993, Judith and Kenneth Harrison boarded their *61 private aircraft in Roosevelt, Utah.

Seagate Tech. v. Commissioner

1999 U.S. Tax Ct. LEXIS 64 · United States Tax Court · Sep 2, 1999

AND CONSOLIDATED SUBSIDIARIES, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Seagate Tech. v. Commissioner Docket No. 19447-97 United States Tax Court 1999 U.S. Tax Ct. … BROWN Chief Counsel Internal Revenue Service Date: August 31, 1999 Date: August 30, 1999 UNITED STATES TAX COURT SEAGATE TECHNOLOGY, INC. AND CONSOLIDATED SUBSIDIARIES, Petitioners, v.

Bell v. Commissioner

85 T.C. 436 · United States Tax Court · Sep 5, 1985

As we said in Hatfield v. … As we said in Abrams v.

McGuire v. Commissioner

44 T.C. 801 · United States Tax Court · Sep 13, 1965

See Heiner v. Crosby , 24 F. 2d 191 ; Doric Apartment Co. v. … Anderson v. Commissioner, 250 F. 2d 242 , 249 *811 (5 Cir. 1957), cert. denied 356 U.S. 950 ; Alvary v. United States, 302 F. 2d 790 , 795 (2 Cir. 1962); Webster Investors Inc. v.

Eli Lilly & Co. v. Commissioner

84 T.C. 996 · United States Tax Court · May 28, 1985

V. … Board of Directors, Officers, and Management Committees During the years 1965 through 1973, Lilly P.R.’s board of directors consisted of from 9 to 11 individuals.

Centralia Federal Sav. & Loan Asso. v. Commissioner

66 T.C. 599 · United States Tax Court · Jun 28, 1976

Petitioners’ deposits are insured by the Federal Savings & Loan Insurance Corp., and petitioners are subject to the regulatory powers of the Federal Home Loan Bank Board. … Citizens Federal Savings & Loan Assn. of Cleveland v. United States, 290 F.2d 932, 937 (Ct.

Christensen v. Comm'r

90 T.C.M. 642 · United States Tax Court · Dec 29, 2005

See Bernal v. Commissioner, 120 T.C. 102 (2003). … See Goldin v. Commissioner, T.C. Memo. 2004-129; Brown v. Commissioner, T.C. Memo. 2002-187. We lack jurisdiction to grant petitioner relief under section 6013(e) for any of the years 1989 through and 1992.