Case law

Pechtel v. United States

18 T.C. 851 · United States Tax Court · Aug 7, 1952

Larrabee v. Stimson, 17 T. C. 69 ; Beeley v. W. C. P. A. B., 12 T. C. 61 ; Grob Brothers v. Secretary of War, 9 T. C. 495 ; Stein Brothers Manufacturing Co v. Secretary of War, 7 T. C. 863 . … extent of subcontracting, and rate of turn-over ; (vii) such other factors the consideration of which the public interest and fair and equitable dealing may require, which factors shall be published in the regulations of the Board

Froman Trust v. Commissioner

58 T.C. 512 · United States Tax Court · Jun 20, 1972

McCreery v. Burmood, 332 Ill. 645 , 164 N.E. 135 (1928); Board of Administration v. Stead, 259 Ill. 194 , 102 N.E. 173 (1913). … Compare Rand v. United States, supra; First National Bank in Palm Beach v. United States, supra; Miami Beach First National Bank v. United States, supra; Florida Bank at Lakeland v.

Shield Co. v. Commissioner

2 T.C. 763 · United States Tax Court · Sep 28, 1943

And in Penn. v. … In Farmville Oil & Fertilizer Co. v.

Mottahedeh v. Comm'r

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

In Weimerskirch v. … In Palmer v.

W. & B. Liquidating Corp. v. Commissioner

71 T.C. 493 · United States Tax Court · Jan 2, 1979

Central Tablet Manufacturing Co. v. … Petitioners rely on Estate of Goodman v. United States, 199 F.2d 895 (3d Cir. 1952), and Estate of Morris v.

Adnee v. Commissioner

41 T.C. 40 · United States Tax Court · Oct 10, 1963

Adnee, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent Adnee v. Commissioner Docket Nos. 94686, 94687, 94688 United States Tax Court 41 T.C. 40 ; 1963 U.S. Tax Ct. … He kept in touch with the market by subscribing to services reporting on market conditions, attending "board" rooms in the broker's offices, and receiving daily reports from the broker concerning securities in which he was

University Chevrolet Co. v. Commissioner

16 T.C. 1452 · United States Tax Court · Jun 29, 1951

University Chevrolet Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent University Chevrolet Co. v. Commissioner Docket No. 27672 United States Tax Court 16 T.C. 1452 ; 1951 U.S. Tax Ct. … His son and an employee held one share each and constituted, with him, the Board of Directors.

United Nat'l Corp. v. Commissioner

2 T.C. 111 · United States Tax Court · Jun 15, 1943

Flanagan v. Helvering, 116 Fed. (2d) 937; Smith v. United States, 121 Fed. (2d) 692. … See Vesper Co. v. Commissioner, 131 Fed. (2d) 200.

Sciortino v. Commissioner

31 T.C.M. 1073 · United States Tax Court · Oct 19, 1972

Sciortino v. Commissioner. Sciortino v. Commissioner Docket No. 1156-71. United States Tax Court T.C. Memo 1972-218 ; 1972 Tax Ct. Memo LEXIS 40 ; 31 T.C.M. (CCH) 1073 ; T.C.M. … If a third or fourth child was attending the school, each received a 20-percent discount on his tuition and board. 1075 The tuition and board at St. Vincent de Paul Seminary for the 1965-1966 school year were $500.

Cory H. Smith

United States Tax Court · Aug 25, 2022

See Brown v. United States, 22 F.4th 1008 (Fed. Cir. 2022). … Furnish v. Commissioner, 262 F.2d 727, 733 n.6 (9th Cir. 1958) (quoting Brown v. Pierce, 74 U.S. 205, 214 (1868)), aff’g in part, rev’g in part 29 T.C. 279 (1957).

Hughes v. Commissioner

67 T.C.M. 2561 · United States Tax Court · Mar 30, 1994

HUGHES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; BRYAN WILLIAM HUGHES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Hughes v. … While the minutes of board meetings that are in evidence state that certain matters were decided by ULC-LB's board of directors, the Court is not convinced that such board of directors meetings actually took place.

Page v. Commissioner

51 T.C.M. 1351 · United States Tax Court · Jul 3, 1986

During July 1979, Ralph Brown and petitioner's brother, Steven Page, were added to the Board of Trustees upon the advice of petitioners' attorney in order to give the Board of Trustees the appearance of independence from … Code, as the Board of Trustees shall determine.

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.

Redwood Empire Sav. & Loan Asso. v. Commissioner

50 T.C.M. 345 · United States Tax Court · Jul 8, 1985

In Adam v. … Commissioner v. Brown, 380 U.S. 563 , 570-571 (1965) .

Cohen v. Commissioner

15 T.C. 261 · United States Tax Court · Sep 22, 1950

Tompkins v. Commissioner, supra, and Denny v. Guyton, 327 Mo. 1030 , 40 S. W. (2d) 562 . … Blair v. Commissioner, supra; Harrison v. Schaffner, 312 U. S. 579 ; and Helvering v. Horst, supra.

Sapson v. Comm'r

49 T.C. 636 · United States Tax Court · Mar 15, 1968

See James v. United States, 308 F. 2d 204 , 10 AFTR 2d 5627, (9th Cir. 1962). … The case of Burns v.

San Francisco Stevedoring Co. v. Commissioner

5 T.C.M. 837 · United States Tax Court · Oct 2, 1946

The San Francisco Stevedoring Co. v. Commissioner. * San Francisco Stevedoring Co. v. Commissioner Docket No. 7775. United States Tax Court 1946 Tax Ct. Memo LEXIS 71 ; 5 T.C.M. (CCH) 837 ; T.C.M. … Coast was not required to repay the money at any certain time but only when Coast had funds available and its Board of Directors should decide to liquidate the loan. That time might never come.

Estate of Burda v. Commissioner

2 T.C.M. 497 · United States Tax Court · Jul 21, 1943

Burda, Louise Burda, Independent Executrix v. Commissioner. Estate of Burda v. Commissioner Docket No. 112690. United States Tax Court 1943 Tax Ct. Memo LEXIS 189 ; 2 T.C.M. (CCH) 497 ; T.C.M. … On appeal the First Circuit, in effect, affirmed the Board's holding that the question of fair market value is always one of fact and never one of formula, but reversed the Board in its conclusion that the stock was worth

Hash v. Commissioner

4 T.C. 878 · United States Tax Court · Feb 28, 1945

Rose Mary Hash, Petitioner, v. Commissioner of Internal Revenue, Respondent. G. Lester Hash, Petitioner, v. Commissioner of Internal Revenue, Respondent Hash v. … Commissioner v. Barbour , 122 Fed. (2d) 165 ; Commissioner v. Lamont , 127 Fed. (2d) 875 ; Bush v. Commissioner , 133 Fed. (2d) 1005 .

Mazo v. Commissioner

32 T.C.M. 546 · United States Tax Court · Jun 12, 1973

IRWIN MAZO and JULIE MAZO, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Mazo v. Commissioner Docket Nos. 1532-72, 2428-72, 2429-72, 2539-72, 2709-72, 2711-72. United States Tax Court T.C. … of Palmer & Cay, Inc.) were members of its board of directors.