Case law

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

Commercial Union Assurance Co. v. Commissioner

1 T.C. 1166 · United States Tax Court · May 26, 1943

V. … The petitioner relies upon Third Scottish American Trust Co., Ltd. v. United States, supra.

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.

Blaffer v. Commissioner

2 T.C.M. 1117 · United States Tax Court · Dec 15, 1943

Sarah Campbell Blaffer v. Commissioner. Estate of R. L. Blaffer, Deceased, Sarah Campbell Blaffer, John Hepburn Blaffer, Jane Blaffer Owen and Cecil Amelia Blaffer, Executors v. Commissioner. Blaffer v. … V.

Flicker v. Commissioner

29 T.C.M. 1115 · United States Tax Court · Aug 31, 1970

Marvin Flicker and Carol-Ann Flicker, et al. 1 v. Commissioner. Flicker v. Commissioner Docket Nos. 1010-67, 1980-67, 2314-67, 2669-68 - 2690-68. United States Tax Court T.C. Memo 1970-252 ; 1970 Tax Ct. … Bingler v. Johnson, supra, at p. 757 .

Russell v. Commissioner

61 T.C.M. 2909 · United States Tax Court · Jun 12, 1991

Prior to and during 1983, Brown Welding Supply, Inc. … See Perry v. Commissioner , T.C. Memo 1987-447 , affd. 855 F.2d 859 (8th Cir. 1988) , distinguishing McNamara v.

Porter v. Commissioner

88 T.C. 548 · United States Tax Court · Mar 5, 1987

Though nearly 60 years have passed since the Board of Tax Appeals rendered its decision in Reed, the right to control is still the “master test.” Azad v. … In Pope v.

International Bedaux Co. v. Commissioner

17 T.C. 612 · United States Tax Court · Oct 8, 1951

International Bedaux Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent International Bedaux Co. v. Commissioner Docket No. 21656 United States Tax Court 17 T.C. 612 ; 1951 U.S. Tax Ct. … During 1942 Charles and Fern constituted the petitioner's board of directors, and during the taxable year there was no meeting of the board of directors of petitioner.

Ft. Orange Paper Co. v. Commissioner

19 T.C.M. 917 · United States Tax Court · Aug 26, 1960

Fort Orange Paper Company v. Commissioner. Ft. Orange Paper Co. v. Commissioner Docket No. 71962. United States Tax Court T.C. Memo 1960-170 ; 1960 Tax Ct. Memo LEXIS 119 ; 19 T.C.M. (CCH) 917 ; T.C.M. … Brashear, then chairman of the board of petitioner, died. No executive officers of petitioner died between 1943 and Latham's death.

Cartinhour v. Commissioner

3 T.C. 482 · United States Tax Court · Mar 20, 1944

The Circuit Court of Appeals for the Fifth Circuit affirmed the holding of the Board that the petitioner (the husband) was taxable with the income of the trust under the provisions of section 22 (a). … In the latter case the Supreme Court of Tennessee said: (5) Evans v. Evans, supra; Graham v. Graham, supra, Owen v.

Cary v. Commissioner

41 T.C. 214 · United States Tax Court · Nov 15, 1963

Cary, Petitioner, v. Commissioner of Internal Revenue, Respondent Cary v. Commissioner Docket No. 95259 United States Tax Court 41 T.C. 214 ; 1963 U.S. Tax Ct. … Relying on the case of Archbold v. United States , 201 F.

Manhattan Co. of Virginia, Inc. v. Commissioner

50 T.C. 78 · United States Tax Court · Apr 17, 1968

Some customers on the lists, such as a boarding school, may continue to do business with the petitioners indefinitely, but that fact should not obscure the fact that other customers on the Arcade lists are discontinuing to … Morover, the taxpayer in Commissioner v.

Hyatt v. Commissioner

20 T.C.M. 1635 · United States Tax Court · Nov 21, 1961

Watson v. Commissioner, 345 U.S. 544 , affirming 15 T.C. 800 ; Williams v. McGowan, supra. … We cannot regard Jones v.

Trinity Secs. Co. v. Commissioner

9 T.C.M. 1018 · United States Tax Court · Nov 17, 1950

Trinity Securities Company, Inc. v. Commissioner. Trinity Secs. Co. v. Commissioner Docket No. 24803. United States Tax Court 1950 Tax Ct. Memo LEXIS 40 ; 9 T.C.M. (CCH) 1018 ; T.C.M. … The Board of Directors of the petitioner, on November 20, 1944, declared a dividend of two shares of Thermoid stock as a dividend on each share of its stock.

Cerf v. Commissioner

1 T.C. 1087 · United States Tax Court · May 11, 1943

Sanford's Estate v. Commissioner, 308 U. S. 39 ; Burnet v. Guggenheim, 288 U. S. 280 . … In Brown v.

Shane v. Commissioner

70 T.C.M. 1052 · United States Tax Court · Oct 23, 1995

Petitioner boarded his horses at a boarding facility located approximately 20 miles from his residence. … On many of these occasions, rather than commute to his residence only to commute back to the boarding facility 4 or 5 hours later, petitioner testified that he slept in his automobile at the boarding facility.

Sakol v. Commissioner

67 T.C. 986 · United States Tax Court · Mar 23, 1977

See, e.g., Harrison v. Schaffner, 312 U.S. 579 (1941); Helvering v. Horst, supra; Lucas v. Earl, 281 U.S. 111 (1930). … See, e.g., Cleveland Board of Education v. LaFleur, 414 U.S. 632 (1974); Vlandis v. Kline, 412 U.S. 441 (1973); U.S. Dept. of Agriculture v. Murry, 413 U.S. 508 (1973).

New Jersey Mortg. & 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.

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.

Zimco Electric Supply Co. v. Commissioner

30 T.C.M. 878 · United States Tax Court · Aug 25, 1971

Zimco Electric Supply Company v. Commissioner. J. B. Zimmerman, Jr., and Faye Zimmerman v. Commissioner. Zimco Electric Supply Co. v. Commissioner Docket Nos. 3729-67 and 3730-67. United States Tax Court T.C. … Notations such as "El Paso Products Bill Reagan & family" and "Brown Elect. Glenn Brown & family" were jotted down on some individual tabs from the club.