Case law

Kadimah Chapter Kiryat Ungvar v. Comm'r

106 T.C.M. 4 · United States Tax Court · Jul 1, 2013

Schwartz resigned from his position on the board in January 1998. Upon Mr. Schwartz’s resignation, Messrs. Gross and Zachariash joined Mr. Knopfler as members of the board. Mr. … See Kurek v. Commissioner, at *12; Atl. Coast Masonry, Inc. v. Commissioner, at *16.

New Jersey Mortgage & Title Co. v. Commissioner

3 T.C. 1277 · United States Tax Court · Aug 28, 1944

This petition was filed by the corporation upon authorization of its board of directors. No proceeding was instituted by its bondholders. … Nelson Co. v. Helvering, 296 U. S. 374 ; Schweitzer & Conrad, Inc., 41 B. T. A. 533; Muskegon Motor Syndicate v. Commissioner, 134 Fed. (2d) 904.

Chamales v. Commissioner

79 T.C.M. 1428 · United States Tax Court · Feb 3, 2000

Shortly thereafter, Nicole Brown Simpson and Ronald Goldman were murdered, and O.J. Simpson was arrested in connection therewith. … - 4 - During the escrow period, on June 12, 1994, Nicole Brown Simpson and Ronald Goldman were murdered at Ms. Brown Simpson’s condominium in West Los Angeles.

Walston v. Commissioner

17 T.C.M. 714 · United States Tax Court · Jul 16, 1958

Walston v. Commissioner. Walston v. Commissioner Docket No. 60636. United States Tax Court T.C. Memo 1958-138 ; 1958 Tax Ct. Memo LEXIS 89 ; 17 T.C.M. (CCH) 714 ; T.C.M. … Walston v. Mrs. Ozella Walston, Docket No.

Dishal v. Commissioner

76 T.C.M. 793 · United States Tax Court · Nov 10, 1998

Wolf v. Commissioner, 4 F.3d 709, 713 (9th Cir. 1993). Petitioners bear the burden of proving the requisite intent. E.g., Golanty v. … E.g., Hulter v. Commissioner, 91 T.C. 371, 393 (1988); Taube v. Commissioner, 88 T.C. 464, 480 (1987); Golanty v. Commissioner, su ra at 426; sec. 1.1832(a) and (b), Income Tax Regs.

Stark v. Commissioner

29 T.C. 122 · United States Tax Court · Oct 28, 1957

See Deputy v. duPont, 308 U. S. 488, 498 (1940). It accumulates (at a certain rate, here 6 per cent per annum) over the period of use or forbearance of the money. … See Commissioner v. Wheeler, 324 U. S. 542, 546 (1945).

Burke v. Commissioner

54 T.C.M. 350 · United States Tax Court · Aug 27, 1987

ARNOLD BURKE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; NEW RESOURCES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Burke v. … Brown which was the amount of a loan made by Brown to Burke and New Resources in 1980. All the other claims were for amounts invested in Jeremiah 33:3.

Terrell v. Commissioner

14 T.C. 572 · United States Tax Court · Apr 10, 1950

Terrell, Petitioner, v. Commissioner of Internal Revenue, Respondent Terrell v. Commissioner Docket No. 19679 United States Tax Court 14 T.C. 572 ; 1950 U.S. Tax Ct. … The board of directors of the corporation adopted the following resolution on June 20, 1944: Whereas *235 in the year 1927 this Company's President, Mr. E. A. Terrell, entered into an arrangement with Mr. W. G.

McGraw v. Comm'r

98 T.C.M. 522 · United States Tax Court · Nov 30, 2009

Memo. 2009-275 UNITED STATES TAX COURT BRUCE MCGRAW AND NORMA MCGRAW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22519-07. … Brown, Jr., for respondent.

John B. Canepa Co. v. Commissioner

22 T.C.M. 1770 · United States Tax Court · Dec 24, 1963

Canepa Company v. Commissioner. John B. Canepa Co. v. Commissioner Docket No. 95340. United States Tax Court T.C. Memo 1963-337 ; 1963 Tax Ct. Memo LEXIS 12 ; 22 T.C.M. (CCH) 1770 ; T.C.M. … of directors of petitioner, then consisting of John V.

Estate of Minzesheimer v. Commissioner

13 T.C.M. 760 · United States Tax Court · Jul 30, 1954

Estate of Carrie Loew Minzesheimer, Chemical Bank & Trust Company, Executor v. Commissioner. Estate of Minzesheimer v. Commissioner Docket No. 46448. United States Tax Court T.C. Memo 1954-117 ; 1954 Tax Ct. … Brown, Esq., World Center Building, Washington, D.C., for the petitioner. John James O'Toole, Esq., for the respondent.

C. Blake McDowell, Inc. v. Commissioner

67 T.C. 1043 · United States Tax Court · Mar 30, 1977

Wetter Manufacturing Co. v. … See Fulman v. United States, supra. Cf. Ivan Allen Co. v. United States, 422 U.S. 617 (1975).

Wagensen v. Commissioner

74 T.C. 653 · United States Tax Court · Jul 9, 1980

Jordan Marsh Co. v. Commissioner, 269 F.2d 453, 455 (2d Cir. 1959), revg. a Memorandum Opinion of this Court on another point; Biggs v. Commissioner, 69 T.C. 905, 913 (1978). In Koch v. … Respondent relies upon Regals Realty Co. v.

Malden Knitting Mills v. Commissioner

42 T.C. 769 · United States Tax Court · Jul 24, 1964

, wherein both parties thereto intend, or such keeper intends, that such contract shall be, or may be, terminated, closed or settled according to, or upon the basis of, the public market quotations of prices made on any board … Knetseh V. United States, 364 U.S. 361, 3 .67-369. Fabrecka Products Co. v.

Braude v. Commissioner

35 T.C. 1158 · United States Tax Court · Mar 31, 1961

Certainly had the parties waited until the mortgage proceeds were on hand and then distributed the surplus to the shareholders this case would be no different from Glichman v. … Glickman v. Commissioner, supra; Max Mints, supra.

Williams v. Commissioner

3 T.C. 1002 · United States Tax Court · Jun 19, 1944

In this contention he relies upon Trippett v. Commissioner, 118 Fed. (2d) 761, affirming 41 B. T. A. 1254; certiorari denied, 314 U. S. 644 . … The board of directors and the sole stockholder had adopted resolutions to dissolve on March 25, and on March 31 all documents required for the dissolution of the corporation were executed and mailed to New York to be filed

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.

Kennedy v. Commissioner

32 T.C.M. 52 · United States Tax Court · Jan 23, 1973

Deputy v. du Pont, 308 U.S. 488 , 499 (1940) . … Richmond Television Corp. v.

Chapman v. Commissioner

32 T.C. 599 · United States Tax Court · Jun 9, 1959

Chapman, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent Chapman v. Commissioner Docket No. 60098 United States Tax Court 32 T.C. 599 ; 1959 U.S. Tax Ct. … applicable here, for in that case gift taxes had been paid on the gifts made in both years involved. *604 The respondent computes the credit for 1951 gifts under the second limitation, above, as follows: Donees : Grace Brown

Prichard Funeral Home v. Comm'r

21 T.C.M. 1399 · United States Tax Court · Nov 5, 1962

Andrews, 23 T.C. 1026 (1955) ; South Dade Farms v. Commissioner, 138 F. 2d 818 (C.A. 5, 1943), affirming a Memorandum Opinion of the Board of Tax Appeals; Brown v. Helvering, 291 U.S. 193 (1934) ; Automobile Club v. … The identical argument was proffered by the taxpayers in Brown v. Helvering, supra.