Case law

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 .

Hopkins v. Commissioner

13 T.C. 952 · United States Tax Court · Dec 20, 1949

Helvering, supra; Helvering v. Louis, 77 Fed. (2d) 386; Commissioner v. Smiley, 86 Fed. (2d) 658; Edwards v. Commissioner, 102 Fed. (2d) 757; and Steinbach Kresge Co. v. Sturgess, 33 Fed. Supp. 897. … Mason Trust v.

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.

Nwachukwu v. Commissioner

79 T.C.M. 1411 · United States Tax Court · Jan 21, 2000

See Turay v. Commissioner, T.C. Memo. 1999-315; Hopkins v. Commissioner, T.C. Memo. 1992-326. … See Cremona v. Commissioner, 58 T.C. 219 (1972); Primuth v. Commissioner, 54 T.C. 374 (1970).

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.

Catalano v. Commissioner

76 T.C.M. 1029 · United States Tax Court · Dec 23, 1998

Business discussions took place on board. Occasionally, the clients were accompanied by their spouses. … Petitioner watched television on the Mainship with his guests, and he used the stereo whenever he was on board. He kept three sets of binoculars on board which his guests could use.

Frazier v. Commissioner

68 T.C.M. 253 · United States Tax Court · Jul 27, 1994

Browne. … Browne, were not personal to him.

Trohimovich v. Commissioner

77 T.C. 252 · United States Tax Court · Aug 10, 1981

See Cupp v. Commissioner, 65 T.C. 68 (1975); Hatfield v. Commissioner, 68 T.C. 895 (1977). … He relied upon a recent Supreme Court case, Thomas v. Review Board of Indiana, decided April 6, 1981, which he apparently had just come upon. That case is inapposite here.

Moore v. Commissioner

85 T.C. 72 · United States Tax Court · Jul 25, 1985

See, e.g., Flowers v. Commissioner, 80 T.C. 914, 937 (1983); Siegel v. Commissioner, 78 T.C. 659, 685 (1982); Brannen v. Commissioner, 78 T.C. 471, 494, 498 (1982), affd. 772 F.2d 695 (11th Cir. 1984); Reali v. … In this connection, compare Saviano v.

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).

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.