Case law

Baker v. Comm'r

118 T.C. 452 · United States Tax Court · May 29, 2002

In Foxe v. … Schelble v. Commissioner, 130 F.3d at 1394 (quoting Iowa v. McFarland, 110 U.S. 471, 478 (1885)); see also Commissioner v. Brown, 380 U.S. 563, 570 (1965).

Huckins Tool & Die, Inc. v. Commissioner

18 T.C.M. 856 · United States Tax Court · Oct 13, 1959

Huckins Tool & Die, Inc. v. Commissioner. Huckins Tool & Die, Inc. v. Commissioner Docket No. 67308. United States Tax Court T.C. Memo 1959-190 ; 1959 Tax Ct. Memo LEXIS 57 ; 18 T.C.M. (CCH) 856 ; T.C.M. … Richard was on the board of directors of petitioner and regularly attended directors' meetings. Robert J.

Homestead Bldg. & Loan Asso. v. Commissioner

18 T.C.M. 614 · United States Tax Court · Jun 30, 1959

Homestead Building and Loan Association, a dissolved corporation v. Commissioner. Homestead Bldg. & Loan Asso. v. Commissioner Docket No. 70997. United States Tax Court T.C. Memo 1959-139 ; 1959 Tax Ct. … A petition filed for and on behalf of a wholly dissolved corporation does not give this Board [now the Tax Court] jurisdiction."

Patterson v. Commissioner

49 T.C.M. 670 · United States Tax Court · Feb 4, 1985

At no time did Jerrico's board *588 bind its representatives to effectuate such an allocation. … See also Theophelis v. United States, F.2d (6th Cir. 1984) ; Markham & Brown, Inc. v. United States, 648 F.2d 1043 (5th Cir. 1981) ; Better Beverages, Inc. v.

Steubenville Bridge Co. v. Commissioner

11 T.C. 789 · United States Tax Court · Nov 8, 1948

As was said by Judge Hand in Chisholm v. … Meurer Steel Barrel Co. v. Commissioner, 144 Fed. (2d) 282. In this decision the court distinguished Chisholm v.

Hagner v. Commissioner

14 T.C. 643 · United States Tax Court · Apr 19, 1950

Hagner, Petitioner, v. Commissioner of Internal Revenue, Respondent. Celina C. Hagner, Petitioner, v. Commissioner of Internal Revenue, Respondent Hagner v. … hereby fixed as the sum of $ 12,000 per year, payable in twelve equal monthly installments of $ 1,000 each, effective April 1, 1941, the same to continue hereafter on said basis until changed by the further action of this board

Trump Village Section 3 v. Commissioner

69 T.C.M. 2985 · United States Tax Court · Jun 22, 1995

See Hoptowit v. Ray , 682 F.2d 1237 , 1260 (9th Cir. 1982) ; Strasser v. Doorley , 432 F.2d 567 , 569 (1st Cir. 1970) ; Erwin v. Commissioner , T.C. Memo. 1986-474 ; Leigh v. Engle , 535 F. Supp. 418 (N.D. Ill. 1982) . … In Puget Sound Plywood, Inc. v.

Shaw Constr. Co. v. Commissioner

35 T.C. 1102 · United States Tax Court · Mar 21, 1961

Higgins v. Smith, 308 U.S. 473 (1940). The incidence of taxation depends on the substance of the transaction, Commissioner v. … Also, the supervisory agent of the Federal Home Loan Bank Board testified that he saw no advantage to the savings and loan associations in splitting these loans and that the Board would have frowned on this practice had it

Spero v. Commissioner

30 T.C. 845 · United States Tax Court · Jun 30, 1958

Brown, Jr., 19 T. C. 87 ; and Johnson v. Commissioner, (C. A. 5) 162 F. 2d 844 . … But see Trust of Bingham, v. Commissioner, 325 U. S. 365 ; and Loyd v. United States, 153 F. Supp. 416 .

St. Louis, Rocky Mountain & Pacific Co. v. Commissioner

28 T.C. 28 · United States Tax Court · Apr 15, 1957

In Sheridan-Wyoming Coal Co. v. … Sheridan-Wyoming Coal Co. v. Helvering, supra; Guanacevi Mining Co., supra; and St. Mary's Oil & Gas Co., supra.

Ferguson v. Commissioner

47 T.C. 11 · United States Tax Court · Oct 17, 1966

The reversal of our opinion in United Mercantile by Drybrough has been followed in Thompson v. United States, 214 F. Supp. 97 (N.D. Ohio 1962); and Demmon v. … On page 739 of 238 F. 2d, the court in Drybrough expressly states that it is persuaded by the reasoning of the Board in Alworth.

Husky Oil Co. v. Commissioner

83 T.C. 717 · United States Tax Court · Nov 23, 1984

Weinert’s Estate v. Commissioner, 294 F.2d 750, 755 (5th Cir. 1961). In United States v. … We held in Weaver v.

Russell Shappy, Jr. & Linda B. Shappy

United States Tax Court · Jan 3, 2024

Lyeth v. … V.

USAA Life Ins. Co. v. Commissioner

94 T.C. 499 · United States Tax Court · Mar 26, 1990

United States v. Price, 361 U.S. 304, 313 (1960), quoted in Estate of Stoll v. Commissioner, 38 T.C. 223, 247 (1962). … Mars, Inc., & Uncle Ben’s, Inc. v. Commissioner, 88 T.C. 428, 435 (1987); National Savings Life Insurance Co. v.

Spahn & Rose Lumber Co. v. Commissioner

1 T.C.M. 181 · United States Tax Court · Dec 8, 1942

Spahn & Rose Lumber Company v. Commissioner. Spahn & Rose Lumber Co. v. Commissioner Docket No. 106747. United States Tax Court 1942 Tax Ct. Memo LEXIS 55 ; 1 T.C.M. (CCH) 181 ; T.C.M. … In Commissioner v.

Estate of Lennard v. Commissioner

61 T.C. 554 · United States Tax Court · Jan 29, 1974

Piedmont Minerals Co. v. United States, 429 F. 2d 560, 563 (C.A. 4, 1970). … Kraft Foods Co. v. Commissioner, 232 F. 2d 118, 125-126 (C.A. 2, 1956).

Huebl v. Commissioner

69 T.C.M. 2264 · United States Tax Court · Mar 28, 1995

CHARLENE HUEBL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Huebl v. Commissioner Docket No. 540-92 United States Tax Court T.C. Memo 1995-134 ; 1995 Tax Ct. Memo LEXIS 180 ; 69 T.C.M. … The Transfer Refund Relief Program was created in 1991 by agreement between the Internal Revenue Service (IRS) and the Board of Trustees of the Maryland State Retirement and Pension Systems (the Board).

Barnett Banks, Inc. v. Comm'r

83 T.C.M. 16 · United States Tax Court · Jul 10, 2002

Loan Corp. v. … Sav. & Loan Co. v.

H. K. Porter Co. v. Commissioner

87 T.C. 689 · United States Tax Court · Sep 29, 1986

See Commissioner v. Spaulding Bakeries, supra. … In Weiss v.

Shipley v. Commissioner

17 T.C. 740 · United States Tax Court · Oct 31, 1951

Shipley, Petitioner, v. Commissioner of Internal Revenue, Respondent Shipley v. Commissioner Docket No. 29339 United States Tax Court 17 T.C. 740 ; 1951 U.S. Tax Ct. … He has organized and been an officer in various manufacturing companies, and is chairman of the board of the Elliott Company, which operates four manufacturing plants.