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).

Cornwell v. Commissioner

37 T.C. 688 · United States Tax Court · Jan 15, 1962

Ailes, Administratrix, Petitioner, v. Commissioner of Internal Revenue, Respondent Cornwell v. Commissioner Docket No. 69458 United States Tax Court 37 T.C. 688 ; 1962 U.S. Tax Ct. … Brown, Jr., Esq ., for the respondent. Mulroney, Judge . MULRONEY *688 OPINION. The respondent determined a deficiency in estate tax in the Estate of John J. Cornwell in the amount of $ 5,384.14.

Los Angeles & S. L. R. Co. v. Commissioner

4 T.C. 634 · United States Tax Court · Jan 30, 1945

United States v. Ludey , 274 U.S. 295 . … Higgins v. Smith , 308 U.S. 473 .

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.

Wood v. Commissioner

57 T.C. 220 · United States Tax Court · Nov 15, 1971

Wood, Petitioners v. Commissioner of Internal Revenue, Respondent Wood v. Commissioner Docket No. 6865-70SC United States Tax Court 57 T.C. 220 ; 1971 U.S. Tax Ct. … Such constitution and bylaws further provided that: "A National Convention shall be held once each year at such time and place as shall be determined by the Executive Board.

ROCHELLE v. COMMISSIONER OF INTERNAL REVENUE

116 T.C. 356 · United States Tax Court · May 24, 2001

United States, 633 F.2d 114 , 117-118 (8th Cir. 1980) (relating to the definition of “public utility property” for investment credit purposes); Warrensburg Board & Paper Corp. v. … See, e.g., Adams v.

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.

Louisquisset Golf Club, Inc. v. Commissioner

21 T.C.M. 1577 · United States Tax Court · Dec 19, 1962

Louisquisset Golf Club, Inc. v. Commissioner. Louisquisset Golf Club, Inc. v. Commissioner Docket No. 84752. United States Tax Court T.C. Memo 1962-297 ; 1962 Tax Ct. Memo LEXIS 10 ; 21 T.C.M. (CCH) 1577 ; T.C.M. … The Board of Directors may pay dividends on the common stock out of the balance of the net profits or surplus as determined by said Board provided the dividends upon the preferred stock with all accumulations shall have been

Putanec v. Comm'r

112 T.C.M. 620 · United States Tax Court · Dec 6, 2016

Inc. v. … See Bridges v.

Slover v. Commissioner

6 T.C. 884 · United States Tax Court · Apr 29, 1946

Slover, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent Slover v. Commissioner Docket Nos. 7557, 7573, 7592, 7593, 7594, 7595 United States Tax Court 6 T.C. 884 ; 1946 U.S. Tax Ct. … Cf. ; V. ↩ ; .

American Mfg. Co. v. Commissioner

55 T.C. 204 · United States Tax Court · Oct 29, 1970

We find nothing in the opinions of Bazley v. Commissioner, 331 U.S. 737 (1947), and Gregory v. … Reddington Co. v.

Estate of Schneider v. Comm'r

29 T.C. 940 · United States Tax Court · Feb 25, 1958

Holland v. United States, 848 U. S. 121 (1954). … Helvering v. Clifford, 309 U. S. 331 (1940) ; Regs. 111, sec. 29.22 (a)-21. It was not reported on his returns.

Russell E. Barrios

United States Tax Court · Mar 14, 2023

United States v. Osuagwu, 858 F. App’x 137, 144 (5th Cir. 2021) (quoting United States v. Brown, 553 F.3d 768, 792 (5th Cir. 2008)). Mr. Barrios relied on the testimony of Mr. … See Brown v. Commissioner, T.C. Memo. 2016-39, at *2–3; Shah, T.C. Memo. 2015-31, at *43. In summary, the “lack of documentary evidence . . . combined with the noncompelling nature of [Mr.

Gustafson v. Commissioner

3 T.C. 998 · United States Tax Court · Jun 13, 1944

Gustafson, Petitioner, v. Commissioner of Internal Revenue, Respondent Gustafson v. Commissioner Docket No. 1769 United States Tax Court 3 T.C. 998 ; 1944 U.S. Tax Ct. … The Board *107 said: We are convinced that the terms "personal, living or family expenses" referred to in section 215 * * * were intended by the Congress to be applied in the ordinarily accepted sense of those words and not

Collup v. Commissioner

21 T.C.M. 128 · United States Tax Court · Feb 12, 1962

Collup and Catherine Collup v. Commissioner. Collup v. Commissioner Docket No. 85925. United States Tax Court T.C. Memo 1962-28 ; 1962 Tax Ct. Memo LEXIS 279 ; 21 T.C.M. (CCH) 128 ; T.C.M. … Helvering v. Owens, 305 U.S. 468 (1938) . *289 The question here involved is, therefore, entirely one of fact.

Norwest Corp. v. Comm'r

108 T.C. 265 · United States Tax Court · Apr 28, 1997

Garcia v. Commissioner, 80 T.C. 491, 498 (1983) (citing Commissioner v. Court Holding Co., 324 U.S. 331 (1945)); see also Gregory v. Helvering, 293 U.S. 465 (1935); Golsen v. … Trading Corp. v.

Estate of Headrick v. Comm'r

93 T.C. 171 · United States Tax Court · Aug 7, 1989

In Estate of Leder v. … In Estate of Leder v.

International Minerals & Chemical Corp. v. Commissioner

47 T.C.M. 1350 · United States Tax Court · Mar 26, 1984

Commissioner v. Brown, 380 U.S. 563 , 579-580 (1965) (Harlan, J., concurring). … Frank Lyon was Lyon's majority shareholder and board chairman and also served on Worthen Bank's board of directors. ↩ 21.

Hornung v. Commissioner

47 T.C. 428 · United States Tax Court · Jan 27, 1967

The Supreme Court in Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955), and General Investors Co. v. … See Palmer v. Commissioner, 802 U.S. 63 (1937); Commissioner v. LoBue, 351 U.S. 243 (1956).

Martin Bros. Box Co. v. Commissioner

1 T.C.M. 999 · United States Tax Court · Apr 22, 1943

The Martin Brothers Box Company v. Commissioner. Martin Bros. Box Co. v. Commissioner Docket No. 110397. United States Tax Court 1943 Tax Ct. Memo LEXIS 351 ; 1 T.C.M. (CCH) 999 ; T.C.M. … The first provided that Southern Kraft would sell to the petitioner 1,500 tons per month of Kraft board for the manufacture of corrugated board in sheet form; that the contract should run from February 1, 1934, to January