Case law

Altera Corp. v. Comm'r

145 T.C. 91 · United States Tax Court · Jul 27, 2015

Mining Cong. v. Mine Safety & Health Admin., 995 F.2d 1106, 1109 (D.C. Cir. 1993)); see also Chrysler Corp. v. Brown, 441 U.S. 281, 301–302 (1979). … V.

Greenspun v. Commissioner

3 T.C.M. 341 · United States Tax Court · Apr 12, 1944

Greenspun et al. 1 v. Commissioner. Greenspun v. … Gregory v. Helvering, 293 U.S. 465 ; Griffths v. Helvering, 308 U.S. 355 ; Higgins v. Smith, 308 U.S. 473 . In Higgins v.

Overton v. Commissioner

6 T.C. 304 · United States Tax Court · Feb 28, 1946

Overton, Petitioner, v. Commissioner of Internal Revenue, Respondent. George W. Oliphant, Petitioner, v. Commissioner of Internal Revenue, Respondent Overton v. … of directors, noncumulative dividends at the rate of $ 10 a share each year before paying dividends on class B stock in such year; that, if the board of directors should decide in their discretion that dividends might in

Madison Newspapers, Inc. v. Commissioner

47 T.C. 630 · United States Tax Court · Mar 24, 1967

Paul v. Commissioner, 206 F. 2d 763 (C.A. 3, 1953) ; Fred Draper, 32 T.C. 545 (1959). … Thus, Congress in effect adopted the rationale of Paul v.

Wilkinson v. Commissioner

29 T.C. 421 · United States Tax Court · Dec 6, 1957

Coudon v. Tait, 56 F. 2d 208 . In United States v. Phellis, 257 U. … This same argument was rejected in De Coppet v.

Damski v. Commissioner

29 T.C. 1 · United States Tax Court · Oct 8, 1957

Paul Damski, Petitioner, v. Commissioner of Internal Revenue, Respondent Damski v. Commissioner Docket No. 54929 United States Tax Court 29 T.C. 1 ; 1957 U.S. Tax Ct. … The money was wrapped in brown paper and sealed with red wax. On the outside of the package it was written "Belongs to Paul Damski." Robins then gave petitioner a receipt for the money.

Lando Products, Inc. v. Commissioner

17 T.C.M. 652 · United States Tax Court · Jun 27, 1958

Lando Products, Inc., a corporation v. Commissioner. Lando Products, Inc. v. Commissioner Docket No. 61311. United States Tax Court T.C. Memo 1958-122 ; 1958 Tax Ct. Memo LEXIS 106 ; 17 T.C.M. (CCH) 652 ; T.C.M. … Gem Jewelry Co., Inc., v. Commissioner, 165 Fed. (2d) 991 , certiorari denied 334 U.S. 846 ; Levine & Bros., Inc., v. Commissioner, 101 Fed. (2d) 391 .

Harmston v. Commissioner

61 T.C. 216 · United States Tax Court · Nov 14, 1973

Brown Lumber Co. v. Commissioner, 59 App. D.C. 110 , 35 F. 2d 880 . Transfer of possession is also significant. Helvering v. Nibley-Mimnaugh Lumber Co., 63 App. D.C. 181 , 70 F. 2d 843 ; Commissioner v. Union Pac. R. … Commissioner v. North Jersey Title Ins. Co., 3 Cir., 79 F. 2d 492 ; Brunton v. Commissioner, supra; Case v. Commissioner, 9 Cir., 103 F. 2d 283 ; United States v. Utah-Idaho Sugar Co., 10 Cir., 96 F. 2d 756 .

Suder v. Comm'r

108 T.C.M. 354 · United States Tax Court · Oct 1, 2014

for manufacturing prototype boards. … , and GTECH for manufacturing prototype boards.

I. Lewis Corp. v. Commissioner

22 T.C.M. 35 · United States Tax Court · Jan 15, 1963

Co. v. … See Brown v. Helvering, 291 U.S. 193 ; Commissioner v. O.

Estate of Douglas v. Commissioner

32 T.C.M. 5 · United States Tax Court · Jan 3, 1973

Commissioner v. Estate of Church, 335 U.S. 632 (1949) . … Guynn v. United States, 437 F.2d 1148 (C.A. 4, 1971); Skinner's Estate v. United States, 316 F.2d 517 (C.A. 3, 1963); McNichol's Estate v. Commissioner, supra ; Estate of Ethel R. Kerdolff, supra ; Estate of Marie J.

Dawson-Spatz Packing Co. v. Commissioner

34 T.C. 507 · United States Tax Court · Jun 16, 1960

Dawson-Spatz Packing Company (Formerly Dawson Packing Company), Petitioner, v. Commissioner of Internal Revenue, Respondent Dawson-Spatz Packing Co. v. … Bernard Brown, Esq ., for the petitioner. Arthur Clark, Jr., Esq ., for the respondent. Forrester, Judge .

Pulsar Components Int'l v. Commissioner

71 T.C.M. 2436 · United States Tax Court · Mar 14, 1996

Board Resolution Concerning Undercompensation Petitioner's board met on August 6, 1984, and reported that each of the Officers was actually paid less than the amounts that were fixed in their employment agreements … Its board decided that petitioner would pay this liability during the year in issue.

Kovens v. Commissioner

91 T.C. 74 · United States Tax Court · Jul 20, 1988

Brown , and Royal B. Martin, Jr ., for the petitioners. Thomas R. Ascher , for the respondent. Gerber , Judge . … Taylor v.

Goldstein v. Commissioner

24 T.C.M. 1141 · United States Tax Court · Aug 17, 1965

Sam Goldstein and Fay Goldstein v. Commissioner. Goldstein v. Commissioner Docket No. 5285-63. United States Tax Court T.C. Memo 1965-223 ; 1965 Tax Ct. Memo LEXIS 107 ; 24 T.C.M. (CCH) 1141 ; T.C.M. … The executive board of Local 239 agreed that all legal expenses and fees incurred in defending petitioner would be borne by the Union. This decision was initially made on June 21, 1956.

Stewart v. Commissioner

8 T.C.M. 998 · United States Tax Court · Nov 22, 1949

Kirk Stewart v. Commissioner. Stewart v. Commissioner Docket No. 19056. United States Tax Court 1949 Tax Ct. Memo LEXIS 31 ; 8 T.C.M. (CCH) 998 ; T.C.M. … Okie, a member of the Audit Review Board of the office of the Collector of Internal Revenue of the District of Michigan.

Ballantine v. Commissioner

74 T.C. 516 · United States Tax Court · Jun 4, 1980

Rule 25(c); 7 Dixon v. Commissioner, 60 T.C. 802, 804 (1973); Estate of Quirk v. Commissioner, 60 T.C. 520 (1973); Board of Tax Appeals v. United States ex rel. Shults Bread Co., 37 F.2d 442 (D.C. … Petitioners, citing Helvering v. Taylor, 293 U.S. 507 (1935), and Reineman v.

CF Indus., Inc. v. Commissioner

62 T.C.M. 1249 · United States Tax Court · Nov 25, 1991

Each shareholder patron owns one share of CF's common stock and the board of directors is composed of one representative from each of the shareholder patrons. … Brown, senior vice president in charge of the Special Industries Group at the Harris Trust and Savings Bank in Chicago.

Hampton v. Commissioner

38 T.C. 131 · United States Tax Court · Apr 24, 1962

In support of this contention he cites on brief Boscoe v. Commissioner, 215 F. 2d 478 (C.A. 5, 1954); Chamberlin v. Commissioner, 207 F. 2d 462 (C.A. 6, 1953) ; Caldwell v. … See also, United States v. Malcolm, 282 U.S. 792 (1931).

Harrold v. Commissioner

61 T.C.M. 2925 · United States Tax Court · Jun 17, 1991

HARROLD, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Harrold v. Commissioner Docket No. 18403-89 United States Tax Court T.C. Memo 1991-274 ; 1991 Tax Ct. Memo LEXIS 317 ; 61 T.C.M. … Resolutions of the Board of Trustees authorizing a special thing be done shall be evidence that such act is within its power.