Case law

Miller v. Commissioner

40 T.C.M. 243 · United States Tax Court · Apr 23, 1980

She served on the board of directors and was vice president of the Elizabeth Fry Center, a halfway house for girls coming out of prison. … Brown v. Commissioner , 62 T.C. 551 (1974) , affd. per curiam 523 F. 2d 365 (8th Cir. 1975) ; Ring v. Commissioner , 23 T.C. 950 (1955) .

Lloyd v. Commissioner

24 T.C. 624 · United States Tax Court · Jun 30, 1955

Estate of Malcolm Lloyd, Jr., Mary Dercum Lloyd, The Pennsylvania Company for Banking and Trusts, Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent Lloyd v. … Wister 1912 Lewis Wynne Wister 1914 Children of decedent's brother, Francis V. Lloyd, who died in 1935 Born Francis V. Lloyd, Jr 1908 Nancy Lloyd 1930 Children of decedent's brother, Stacy B.

Barlow v. Commissioner

80 T.C.M. 632 · United States Tax Court · Nov 3, 2000

Freedman (Freedman), a certified public accountant and the named partner in Freedman & Co., was the president, chairman of the board, and 9.1 percent owner of F&G. … Lindstrom also reported that various equipment companies, such as the Cumberland Engineering Division of John Brown Plastics Machinery, were willing to provide customized recycling programs to companies at a minimum cost

Brighton Recreations, Inc. v. Commissioner

20 T.C.M. 127 · United States Tax Court · Jan 31, 1961

Brighton Recreations, Incorporated, a Utah corporation v. Commissioner. Brighton Recreations, Inc. v. Commissioner Docket No. 72172. United States Tax Court T.C. Memo 1961-29 ; 1961 Tax Ct. Memo LEXIS 325 ; 20 T.C.M. … Earle v. W. J. Jones & Son, Inc., 200 F. 2d 846 , 851 (C.A. 9). [ Byerlite Corp. v. Williams, (C.A. 6) 286 F. 2d 285 (Dec. 15, 1960).]

Lundquist v. Commissioner

77 T.C.M. 1556 · United States Tax Court · Mar 19, 1999

She also received $200 for boarding a horse. … See Engdahl  - 27 - v. Commissioner, supra at 669; Phillips v. Commissioner, T.C. Memo. 1997-128; Briggs v. Commissioner, T.C. Memo. 1994-125; Leonard v. Commissioner, T.C.

Honeywell, Inc. v. Commissioner

64 T.C.M. 437 · United States Tax Court · Aug 11, 1992

The six issues that were selected to be analyzed were those that had been analyzed in the Brown Report. … Lucas v.

Mattes v. Commissioner

1 T.C.M. 220 · United States Tax Court · Dec 15, 1942

Mattes v. Commissioner. Mattes v. Commissioner Docket No. 102850. United States Tax Court 1942 Tax Ct. Memo LEXIS 38 ; 1 T.C.M. (CCH) 220 ; T.C.M. (RIA) 42647 ; December 15, 1942 *38 1. … They file their report on or before the tenth day of the annual meeting of the Board of Supervisors. The Board of Supervisors may correct errors (Section 56).

Blum v. Commissioner

5 T.C. 303 · United States Tax Court · Jun 21, 1945

Hill v. Commissioner, 126 Fed. (2d) 570; Cohen Trust v. Commissioner, 121 Fed. (2d) 689; Hammans v. Commissioner, 121 Fed. (2d) 4. … He testified at first that he received his instructions from the board of directors, through the president of the company, to open a treasury account and to mark the stock accordingly.

Estate of Nieman v. Commissioner

17 T.C.M. 105 · United States Tax Court · Feb 19, 1958

Nieman, Executors v. Commissioner. Estate of Nieman v. Commissioner Docket No. 60648. United States Tax Court T.C. Memo 1958-24 ; 1958 Tax Ct. Memo LEXIS 208 ; 17 T.C.M. (CCH) 105 ; T.C.M. … Finneytown Board *210 of Education for $2,800.

Walsh v. Commissioner

66 T.C.M. 704 · United States Tax Court · Sep 13, 1993

WALSH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Walsh v. Commissioner Docket No. 19769-85 United States Tax Court T.C. Memo 1993-421 ; 1993 Tax Ct. Memo LEXIS 432 ; 66 T.C.M. … This Court has decided many cases involving purported financial straddles similar, if not identical, to Freytag , e.g., , affd. sub nom. . 3 Although we did not award damages under section 6673 in Brown , we cautioned the

Bryan v. Commissioner

16 T.C. 972 · United States Tax Court · May 7, 1951

Commissioner v. Farren (C. A. 10, 1936), 82 F. 2d 141 ; Continental Oil Co. v. Jones (C. A. 10, 1949), 177 F. 2d 508 . … Ross v. Commissioner (C. A. 1, 1948), 169 F. 2d 483 , and Bennet v. Helvering (C. A. 2, 1943), 137 F. 2d 537 . We are without jurisdiction to determine a deficiency in excess of the amount determined by respondent.

Richmond Patients Group v. Commissioner

2020 T.C. Memo. 52 · United States Tax Court · May 4, 2020

Four board members operated Richmond, and William Koziol, a board member, served as Richmond’s managing director. Mr. … Brown v. Helvering, 291 U.S. 193, 204 (1934). The Commissioner has authority to give consent retroactively to a change in a taxpayer’s method of computing taxable income that has already been made. See Barber v.

Einstein v. Commissioner

14 T.C.M. 19 · United States Tax Court · Jan 18, 1955

Einstein, et al. 1 v. Commissioner. Einstein v. Commissioner Docket Nos. 35760, 35768, 35781. United States Tax Court T.C. Memo 1955-6 ; 1955 Tax Ct. Memo LEXIS 333 ; 14 T.C.M. (CCH) 19 ; T.C.M. … Brown 2,708.84 35781 G. & N.

Thornton v. Commissioner

5 T.C. 1177 · United States Tax Court · Dec 10, 1945

Warburton v. White, 176 U. S. 484 ; Tyler v. United States, 281 U. S. 497 ; Leser v. Burnet, 46 Fed. (2d) 756; Freuler v. Helvering, 291 U. S. 34 ; Blair v. Commissioner, 300 U. S. 5 ; Sharp v. Commissioner, 303 U. … 78, sec. 1; 114 v. 358.

Richard C. Mathews v. Commissioner

United States Tax Court · Dec 26, 2018

See, e.g., Browning v. Commissioner, T.C. Memo. 2011-261, 2011 WL 5289636, at *10. A. Underpayment Petitioner conceded that he underreported income for 2007 and 2008. … See, e.g., Browning v. Commissioner, 2011 WL 5289636, at *13. Fraudulent intent must exist at the time the taxpayer files the return. Gleis v.

Miglietta v. Commissioner

1 T.C.M. 499 · United States Tax Court · Jan 28, 1943

Miglietta v. Commissioner. Miglietta v. Commissioner Docket No. 108679. United States Tax Court 1943 Tax Ct. Memo LEXIS 486 ; 1 T.C.M. (CCH) 499 ; T.C.M. … The general rule so announced was applied by the Board to the facts in that case. On appeal the , reversed the Board, holding that *498 Congress did not intend that its rule be inelastically and rigidly applied.

I. S. C., Inc. v. Commissioner

37 T.C.M. 1206 · United States Tax Court · Jul 27, 1978

At such meeting, the board of directors approved a fair market value of $ 15,514.56 per share. … Casey v. Commissioner , 38 T.C. 357 , 381 (1962) ; Radio Station WBIR, Inc. v. Commissioner , 31 T.C. 803 , 817 (1959) ; Bullock v.

LEPPIN v. COMMISSIONER

2002 T.C. Summary Opinion 143 · United States Tax Court · Nov 5, 2002

LEPPIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 941-01S. Filed November 5, 2002. Robert B. Leppin, pro se. Sean R. … Railroad Retirement Board (RRB). For that year, petitioner received from the RRB a Form RRB-1099-R, Annuities or Pensions By the Railroad Retirement Board.

John Province 1 Well v. Commissioner

37 T.C. 376 · United States Tax Court · Nov 29, 1961

Morrissey v. Commissioner, supra; Hecht v. Malley, 265 U.S. 144 ; Burk-Waggoner Assn. v. Hopkins, 269 U.S. 110 . … Hecht v. Malley, supra; Burk-Waggoner Assn. v. Hopkins, supra; United States v. Stierwalt, supra.

Lombardo v. Commissioner

50 T.C.M. 1374 · United States Tax Court · Nov 6, 1985

See, e.g., Stubbs v. United States, 428 F.2d 885 (9th Cir. 1970) , and Sutton v. … Commissioner, 51 T.C. 233 (1968) , *85 and DeJong v.