Case law

Cumberland Portland Cement Co. v. Commissioner

29 T.C. 1185 · United States Tax Court · Mar 31, 1958

In Commissioner v. Sunnen, 333 U. … Tait v. Western Md. R. Co., supra. * * * In the petitioner’s former case (44 B. T.

Nutt v. Commissioner

39 T.C. 231 · United States Tax Court · Oct 26, 1962

Respondent relies on Lucas v. Earl, 281 U.S. 111 (1930), Gregory v. Helvering, 293 U.S. 465 (1935), Higgins v. Smith, 308 U.S. 473 (1940), and Commissioner v. Court Holding Co., 324 U.S. 331, 334 (1945). … See Higgins v. Smith, supra.

Hamill Coal Corp. v. Commissioner

14 T.C.M. 218 · United States Tax Court · Mar 23, 1955

Hamill Coal Corporation, a Dissolved Corporation, Frank Correale, Palmer Correale and Fred Correale, Directors at the Time of Dissolution and Statutory Trustees v. Commissioner. Hamill Coal Corp. v. … Brown, 22 T.C. 58 ; and Gregory Run Coal Co. v. Commissioner, 212 Fed. (2d) 52 , certiorari denied 348 U.S. 828 , reversing J. E.

Imler v. Commissioner

11 T.C. 836 · United States Tax Court · Nov 22, 1948

Imler, Petitioner, v. Commissioner of Internal Revenue, Respondent Imler v. Commissioner Docket No. 15670 United States Tax Court 11 T.C. 836 ; 1948 U.S. Tax Ct. … Rheinstrom v. Conner , 125 Fed. (2d) 790 ; certiorari denied, 317 U.S. 654 . No sole or universally applicable test can be laid down. Flanagan v. Helvering , 116 Fed. (2d) 937 .

Thal v. Commissioner

2 T.C.M. 123 · United States Tax Court · May 24, 1943

Joseph Thal v. Commissioner. Thal v. Commissioner Docket No. 109994. United States Tax Court 1943 Tax Ct. Memo LEXIS 289 ; 2 T.C.M. (CCH) 123 ; T.C.M. … He was present at all meetings of the board of directors. We are not concerned with the fact that the value of the stocks when credited to the petitioner's account was much less than their cost.

Goldstone v. Commissioner

52 T.C.M. 660 · United States Tax Court · Sep 25, 1986

We note that in Brown v. Commissioner, F.2d (2d Cir., Aug. 28, 1986) , affg. T.C. … Brown v. Commissioner, supra ; Wing v. Commissioner, supra.

New Amsterdam Fish, Inc. v. Commissioner

30 T.C.M. 80 · United States Tax Court · Jan 21, 1971

New Amsterdam Fish, Inc. v. Commissioner. New Amsterdam Fish, Inc. v. Commissioner Docket Nos. 2853-65, 5406-65. United States Tax Court T.C. Memo 1971-17 ; 1971 Tax Ct. Memo LEXIS 315 ; 30 T.C.M. (CCH) 80 ; T.C.M. … Indeed, *325 if we look to the tenets applied in Lilly v. Commissioner, 343 U.S. 90 (1952) ; Paramount Finance Company v. United States, 304 F. 2d 460 (Ct. Cl. 1962) ; Fiambolis v. United States, 152 F.

Estate of Broadhead v. Commissioner

25 T.C.M. 133 · United States Tax Court · Jan 28, 1966

In Whipple v. … Brown, 1 T.C. 225 (1942) .

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.

Kellett v. Commissioner

5 T.C. 608 · United States Tax Court · Aug 20, 1945

Kellett and Virginia Kellett, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent Kellett v. Commissioner Docket No. 3264 United States Tax Court 5 T.C. 608 ; 1945 U.S. Tax Ct. … Corporation of America, as referred to above, was accepted by the executive committee of the board of directors of the American Gas Accumulator Co. On June 24, 1930, William W.

Maher v. Commissioner

55 T.C. 441 · United States Tax Court · Dec 10, 1970

Crane v. Commissioner, 331 U.S. 1, 12-14 (1947); Smith v. Commissioner, 324 F.2d 725 (C.A. 9, 1963), affirming a Memorandum Opinion of this Court; Teitelbaum v. … Cleveland, supra at 580-581 , the Board stated: In onr opinion tlie first point in petitioners’ contention, as above set out, is without merit.

Pilgrim's Pride Corporation Successor in Interest to Pilgrim's Pride Corporation of Georgia f/k/a Gold Kist, Inc. v. Commissioner

141 T.C. No. 17 · United States Tax Court · Dec 11, 2013

.); Trotz v. … Artists Corp. v.

Brandschain v. Commissioner

80 T.C. 746 · United States Tax Court · Apr 25, 1983

This case is not like Hamm v. … See Abbott v. Commissioner, supra; Hillman v. Commissioner, supra.

Horne Oil Co. v. Commissioner

6 T.C.M. 233 · United States Tax Court · Mar 4, 1947

Horne Oil Company v. Commissioner. Horne Oil Co. v. Commissioner Docket No. 10286. United States Tax Court 1947 Tax Ct. Memo LEXIS 284 ; 6 T.C.M. (CCH) 233 ; T.C.M. (RIA) 47052 ; March 4, 1947 *284 Rice M. … Again, on June 15, 1943, the petitioner's board of directors, in the same manner as on December 9, 1942, and by resolution in the same form, except as to amounts and dates and description of property, resolved to declare

Gulf Oil Corp. v. Commissioner

84 T.C. 447 · United States Tax Court · Mar 18, 1985

Durham Bros. v. Robertson, (1898) 1 Q.B. 765, 772. … Stewart v.

Boston & M. R. Co. v. Commissioner

16 T.C. 1517 · United States Tax Court · Jun 29, 1951

Commissioner v. Union Pacific Railroad, Co., supra; Southern Railway Co. v. … Under the principle of Cohan v.

Gold Seal Liquors, Inc. v. Commissioner

28 T.C. 471 · United States Tax Court · May 28, 1957

Commissioner of Internal Revenue, Respondent Gold Seal Liquors, Inc. v. Commissioner Docket No. 35403 United States Tax Court 28 T.C. 471 ; 1957 U.S. Tax Ct. … A special meeting of the board of directors of Famous was held on April 10, 1940.

Ahmed v. Comm'r

102 T.C.M. 607 · United States Tax Court · Dec 22, 2011

Although petitioner was reinstated with backpay by the Fulton County Personnel Board, he alleged that the harassment continued and even grew worse after he was rehired. … Although he filed a workers’ compensation claim for his hospitalization in January 2005, his claim was denied by the Georgia State Board of Workers’ Compensation.

Alron Eng'g & Testing Corp. v. Commissioner

80 T.C.M. 603 · United States Tax Court · Nov 1, 2000

Memo. 2000-335 UNITED STATES TAX COURT ALRON ENGINEERING & TESTING CORP., Petitioner v. … of not less than 4 years, together with an additional 8 years of experience in engineering work, all satisfactory to the examining board.

Harbor Plywood Corp. v. Commissioner

14 T.C. 158 · United States Tax Court · Jan 31, 1950

Harbor Plywood Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Harbor Plywood Corp. v. Commissioner Docket No. 20729 United States Tax Court 14 T.C. 158 ; 1950 U.S. Tax Ct. … received by this Association in such fiscal year exceeds the amount that has been incurred during said fiscal year for the payment by the Association of its expenses, including the cost of market development, then, unless the Board