Case law

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.

Caulfield v. Commissioner

66 T.C.M. 710 · United States Tax Court · Sep 14, 1993

Brown, Clerk of Circuit Court, within and for the County of St. … BROWN, SUSAN E. BROWN, CLERK BY LESLIE EISENSTEIN, DEPUTY The certification purports to have been signed by a deputy clerk of the circuit court.

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.

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.

Knox v. Commissioner

1 T.C. 575 · United States Tax Court · Feb 11, 1943

Knox, Petitioner, v. Commissioner of Internal Revenue, Respondent Knox v. Commissioner Docket No. 107622 United States Tax Court 1 T.C. 575 ; 1943 U.S. Tax Ct. … On August 7, 1935, petitioner transferred additional securities to the trustees, and for that year reported and paid a gift tax of $ 144,929.73, and, pursuant to decision of the Board of Tax Appeals, a deficiency of $ 1,335

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).

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.

Campbell v. Commissioner

15 T.C. 312 · United States Tax Court · Sep 28, 1950

Robert Campbell, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent Campbell v. … Helvering , 293 U.S. 465 ; *99 "continuity of interest," Helvering v. Minnesota Tea Co ., 296 U.S. 378 ; and "proprietary stake," LeTulle v. Scofield , 308 U.S. 415 .

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.

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.

Wilken v. Commissioner

53 T.C.M. 965 · United States Tax Court · Jun 2, 1987

In Kirchner v. … In Elbert 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.

Mills v. Commissioner

60 T.C.M. 500 · United States Tax Court · Aug 13, 1990

As we pointed out in Schirmer v. … In Schirmer v.

Kean v. Commissioner

91 T.C. 575 · United States Tax Court · Sep 8, 1988

(hereinafter sometimes referred to as Landfill), a wholly owned subsidiary of Browning-Ferris Industries, Inc. … Wilkof v.

Seraydar v. Commissioner

50 T.C. 756 · United States Tax Court · Aug 20, 1968

Seraydar, Petitioner v. Commissioner of Internal Revenue, Respondent Seraydar v. Commissioner Docket No. 2023-66 United States Tax Court 50 T.C. 756 ; 1968 U.S. Tax Ct. … Brown , 48 T.C. 42 (1967) .

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.

Cheyne v. Commissioner

36 T.C.M. 1439 · United States Tax Court · Oct 11, 1977

Helvering v. Mitchell, 303 U.S. 391 (1938) . In Lias v. … Reininger v.