Case law

Farmers Creamery Co. v. Commissioner

14 T.C. 879 · United States Tax Court · May 18, 1950

Farmers Creamery Company of Fredericksburg, Virginia, Petitioner, v. Commissioner of Internal Revenue, Respondent Farmers Creamery Co. v. Commissioner Docket No. 20716 United States Tax Court 14 T.C. 879 ; 1950 U.S. … Wichita Coca-Cola Bottling Co. v. United States , 152 Fed. (2d) 6 ; certiorari denied, 327 U.S. 806 .

Ruggere v. Commissioner

78 T.C. 979 · United States Tax Court · Jun 14, 1982

In Jones v. … Vance v. Bradley, 440 U.S. 93, 97 (1979); Massachusetts Board of Retirement v. Murgia, 427 U.S. 307, 312-314 (1976).

Securitas Holdings, Inc. v. Comm'r

108 T.C.M. 490 · United States Tax Court · Oct 29, 2014

Protectors maintained separate books and records, maintained a separate bank account for its operations, prepared financial statements, and held annual meetings of its board of directors. … Commissioner, 811 F.2d at 1305. 19 Clougherty Packing Co. v. Commissioner, 811 F.2d at 1307 (citing Moline Props., Inc. v.

Raymep Realty Corp. v. Commissioner

7 T.C.M. 262 · United States Tax Court · Apr 30, 1948

Paymer, Directors and Trustees in Liquidation v. Commissioner. Rorden Realty Corp. and/or Samuel S. Paymer and Joseph J. Paymer, Directors and Trustees in Liquidation v. Commissioner. Samuel S. Paymer v. Commissioner. … Dalton v. Bowers, 287 U.S. 404 ; Burnet v. Clark, 287 U.S. 410 ; Burnet v. Commonwealth Improvement Co., 287 U.S. 415 .

Lee Tel. Co. v. Commissioner

16 T.C.M. 1044 · United States Tax Court · Dec 16, 1957

Lee Telephone Company v. Commissioner. Lee Tel. Co. v. Commissioner Docket No. 59011. United States Tax Court T.C. Memo 1957-230 ; 1957 Tax Ct. Memo LEXIS 18 ; 16 T.C.M. (CCH) 1044 ; T.C.M. … The action of the board of directors was ratified by petitioner's sole stockholder on December 6, 1949.

Grandinetti v. Commissioner

32 T.C.M. 361 · United States Tax Court · Apr 10, 1973

DOMINIC and NETTIE GRANDINETTI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Grandinetti v. Commissioner Docket No. 3361-71. United States Tax Court T.C. Memo 1973-81 ; 1973 Tax Ct. … At that time, one of the members of the board raised a question with respect to the ownership of the property.

Bell Oldsmobile, Inc. v. Commissioner

22 T.C.M. 330 · United States Tax Court · Mar 15, 1963

Bell Oldsmobile, Inc. v. Commissioner. Bell Oldsmobile, Inc. v. Commissioner Docket No. 85928. United States Tax Court T.C. Memo 1963-76 ; 1963 Tax Ct. Memo LEXIS 268 ; 22 T.C.M. (CCH) 330 ; T.C.M. … They were its only compensated officers, and were also on *269 its board of directors, which had three members.

Lake v. Commissioner

12 T.C.M. 520 · United States Tax Court · May 15, 1953

Sidney Lake v. Commissioner. Lake v. Commissioner Docket No. 38473. United States Tax Court 1953 Tax Ct. Memo LEXIS 252 ; 12 T.C.M. (CCH) 520 ; T.C.M. (RIA) 53167 ; May 15, 1953 *252 Henry R. … Opinion MURDOCK, Judge: The Commissioner does not dispute the fact that the petitioner spent $2,156 for board and lodging while away from New York in 1948.

Casanova Co. v. Commissioner

87 T.C. 214 · United States Tax Court · Jul 28, 1986

Adickes v. Kress & Co., supra; United States v. Diebold, Inc., 369 U.S. 654, 655 (1962). … Lyons v. Board of Education of Charleston, 523 F.2d 340, 347 (8th Cir. 1975).

Hemenway-Johnson Furniture Co. v. Commissioner

22 T.C. 43 · United States Tax Court · Apr 12, 1954

Hemenway-Johnson Furniture Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Hemenway-Johnson Furniture Co. v. Commissioner Docket No. 27201 United States Tax Court 22 T.C. 43 ; 1954 U.S. Tax Ct. … Petitioner's board of directors declined to do so.

Barton v. Commissioner

28 T.C.M. 261 · United States Tax Court · Mar 10, 1969

Barton v. Commissioner#& Barton v. Commissioner Docket No. 3255-67. United States Tax Court T.C. Memo 1969-46 ; 1969 Tax Ct. Memo LEXIS 251 ; 28 T.C.M. (CCH) 261 ; T.C.M. … Antioch, California March 30 to June 15 Brown Rubber Co.

Dees v. Commissioner

21 T.C.M. 833 · United States Tax Court · Jun 26, 1962

Commissioner v. LoBue, 351 U.S. 243 (1956) , and Commissioner v. Smith, 324 U.S. 177 (1945) . … Guggenheim v. Rasquin, 312 U.S. 254 (1941) , and United States v. General Shoe Corporation, 282 F. 2d 9 , 13 (C.A. 6, 1960).

Buckley v. Commissioner

4 T.C.M. 460 · United States Tax Court · May 1, 1945

Buckley v. Commissioner. Helen Hunter Davis v. Commissioner. Clare E. Good v. Commissioner. Lloyd A. Good v. Commissioner. Mary P. McDaniel v. Commissioner. Ernest B. Loveman v. Commissioner. John S. Thomas, Jr. v. … Heinritz v. Commissioner. Ethel S. Carpenter v. Commissioner. Lloyd A. Good, Jr. Trust v. Commissioner. Jane McLaughlin Timmons v. Commissioner. Buckley v.

Recklitis v. Commissioner

91 T.C. 874 · United States Tax Court · Nov 7, 1988

Consequently, SCA’s board of directors informed petitioner that he had to bring about repayment of the $1,200,000 by June 30, 1975, the date SCA’s Form 10K had to be filed with the SEC. … Miller v. Commissioner, 70 T.C. 448, 455-456 (1978). In W.W. Windle Co. v.

Stanton v. Commissioner

14 T.C. 217 · United States Tax Court · Feb 14, 1950

At a meeting of the board of directors of the Red Wing Malting Co., in December, 1942, Stanton advised his fellow members of the board that a fairly good volume of business could, in his opinion, be developed in the sale … Harrison v. Schaffner , 312 U.S. 579 ; Helvering v. Horst, supra ; Helvering v. Clifford, supra . Where income flows from labor, the issue is, Who "earned" the income? Commissioner v. Tower , 327 U.S. 280 ; Doll v.

Brill v. Commissioner

15 T.C.M. 992 · United States Tax Court · Aug 8, 1956

Jack Brill v. Commissioner. Morris Brill v. Commissioner. Brill v. Commissioner Docket Nos. 53304, 53305. United States Tax Court T.C. Memo 1956-182 ; 1956 Tax Ct. Memo LEXIS 110 ; 15 T.C.M. (CCH) 992 ; T.C.M. … The scarcity had abated by that time and the War Production Board had commenced an investigation to ascertain if the petitioners were selling steel wool for home use or for industrial use.

LANG HER & v. COMMISSIONER

2005 T.C. Summary Opinion 187 · United States Tax Court · Dec 27, 2005

At the time the petition was filed petitioners resided in Brown Deer, Wisconsin. Background In 1995, Michael C. Cooper (Mr. … See, e.g., Cally v. Commissioner, T.C. Memo. 1983-203; Roth v. Commissioner, T.C. Memo. 1981-699.

Kramer v. Commissioner

56 T.C.M. 378 · United States Tax Court · Sep 28, 1988

Larsen v. Commissioner, 89 T.C. 1229 (1987) , James v. … Memo 1987-163 , wherein it was stated that the roles of Brown, J & P and Little Brownie as promoter, lessee and seller cast serious doubt that the "genuine multi-party transaction" test of Frank Lyon Co. v.

J. T. Slocomb Co. v. Commissioner

38 T.C. 752 · United States Tax Court · Aug 29, 1962

The assets in question obviously had some value, however, and, applying the principles of (Cohan v. … Army Times Sales Co., supra at 705; Brown Dynalube Company v. Commissioner, 297 F. 2d 915, 918 (C.A. 4, 1962), affirming a Memorandum Opinion of this Court.

West Dodd Lightning Conductor Corp. v. Commissioner

7 T.C.M. 374 · United States Tax Court · Jun 23, 1948

The board of directors of the petitioner at all times material hereto consisted of the following: Emma V. Hoovens, E. R. Stotts, C. A. Schnoebelen, L. J. Brooks, Jr., John M. *158 Cornell. Emma V. … The board of directors on October 13, 1941, voted a bonus for that year to Emma V. Hoovens and E. R.