Case law

Wilkin v. Commissioner

28 T.C.M. 681 · United States Tax Court · Jun 25, 1969

Wilkin v. Commissioner. Wilkin v. Commissioner Docket No. 2785-67. United States Tax Court T.C. Memo 1969-130 ; 1969 Tax Ct. Memo LEXIS 168 ; 28 T.C.M. (CCH) 681 ; T.C.M. … At the annual meeting of the board of directors of National Plywoods, Inc., held on January 19, 1961, a resolution was unanimously adopted that, "the Corporation purchase from Peter J.

Stegner v. Commissioner

14 T.C.M. 1081 · United States Tax Court · Oct 14, 1955

Stegner v. Commissioner. Stegner v. Commissioner Docket No. 53236. United States Tax Court T.C. Memo 1955-276 ; 1955 Tax Ct. Memo LEXIS 60 ; 14 T.C.M. (CCH) 1081 ; T.C.M. (RIA) 55276 ; October 14, 1955 *60 Mortimer A. … The Commissioner concedes that the first three jobs in 1950 were temporary in nature, and as such the petitioner is entitled to a deduction of $840 for thirty weeks' room and board at $28 per week.

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.

Maxwell v. Commissioner

28 T.C.M. 390 · United States Tax Court · Apr 14, 1969

Maxwell v. Commissioner. Maxwell v. Commissioner Docket No. 1596-67. United States Tax Court T.C. Memo 1969-71 ; 1969 Tax Ct. Memo LEXIS 227 ; 28 T.C.M. (CCH) 390 ; T.C.M. (RIA) 69071 ; April 14, 1969 , Filed James W. … Brown, 48 T.C. 42 .

Geller v. Comm'r

35 T.C.M. 1122 · United States Tax Court · Aug 18, 1976

WILLIAM GELLER and DORIS GELLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Geller v. Comm'r Docket No. 4046-73. United States Tax Court T.C. Memo 1976-257 ; 1976 Tax Ct. Memo LEXIS 146 ; 35 T.C.M. … Brown may have mistaken Morris for petitioner. ↩

Schussel v. Comm'r

149 T.C. No. 16 · United States Tax Court · Oct 5, 2017

Petitioner further stated, citing our Opinion in Wagner v. … Commissioner, 42 F.2d 177 (2d Cir. 1930) (finding that section 6901 evinces “a clear intention to give a transferee the same right as a taxpayer in respect to seeking a review of a proposed assessment by appeal to the Board

Home Team Transition Mgmt. v. Comm'r

113 T.C.M. 1228 · United States Tax Court · Mar 28, 2017

Rule 142(a); Botany Worsted Mills v. United States, 278 U.S. 282 (1929). … In Friendly Fin., Inc. v. Commissioner, T.C. Memo. 1991-551, 1991 Tax Ct.

Palda v. Commissioner

27 T.C. 445 · United States Tax Court · Nov 30, 1956

Randolph Products Co. v. Manning, (C. A. 3) 176 F. 2d 190 . … A. 5) 110 F. 2d 945 , reversing a Memorandum Opinion of the Board of Tax Appeals filed July 25, 1939, certiorari denied 311 U.

Knapp v. Commissioner

90 T.C. 430 · United States Tax Court · Mar 15, 1988

See Wheeler v. United States, supra; Greensboro Pathology Associates, P.A. v. United States, 698 F.2d 1196 (Fed. Cir. 1982); Grant-Jacoby, Inc. v. Commissioner, 73 T.C. 700 (1980); Armantrout v. … See Commissioner v. Gooch Milling Co., 320 U.S. 418 (1943); Lorain Avenue Clinic v. Commissioner, 31 T.C. 141, 164 (1958).

Summit Sheet Metal Co. v. Commissioner

72 T.C.M. 1606 · United States Tax Court · Dec 30, 1996

He was employed as an auditor with the California State Board of Equalization in the late 1940's. … Petitioner's Board of Directors and Officers Chasin, Hanson, and Searing were the only members of petitioner's board of directors from 1964 to the year in issue.

Leonard Refineries, Inc. v. Commissioner

11 T.C. 1000 · United States Tax Court · Dec 7, 1948

A. 173; Commissioner v. Mutual Fertilizer Co., 159 Fed. (2d) 470; and Commissioner v. Cleveland Adolph Mayer Realty Corporation, 160 Fed. (2d) 1012. … United States v. Farrell, 35 Fed. (2d) 38.

F. E. McGillick Co. v. Commissioner

42 T.C. 1059 · United States Tax Court · Sep 18, 1964

At all times involved herein, including the years 1949 through 1956, McGillick and his wife were the sole trustees of the foundation and constituted the board of directors of petitioner. … Co. v. Welch, 304 U.S. 191 (1938); Jacobs v. Commissioner, 224 F. 2d 412 (C.A. 9, 1955); and Peter Mamada, 41 T.C. 572 (1964). In more recent cases this Court has not adhered to the rule set forth in Rev.

August v. Commissioner

30 T.C. 969 · United States Tax Court · Jul 31, 1958

Glickman v. Commissioner, supra; Carl B. Rechner, supra; and Raymond G. Burge, supra. … Glickman v. Commissioner, supra, and Raymond G. Burge, supra.

Simon & Simon v. Commissioner

1 T.C.M. 982 · United States Tax Court · Apr 28, 1943

Simon and Simon v. Commissioner. Simon & Simon v. Commissioner Docket No. 110570. United States Tax Court 1943 Tax Ct. Memo LEXIS 337 ; 1 T.C.M. (CCH) 982 ; T.C.M. … Brown, Esq., for the respondent.

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).

Pediatric Surgical Assocs., P.C. v. Comm'r

81 T.C.M. 1474 · United States Tax Court · Apr 2, 2001

Bianchi v. … Petitioner must prove its intent (i.e., the intent of the members of the board) to pay compensation. See, e.g., Paula Constr. Co. v.

Fields v. Comm'r

107 T.C.M. 1248 · United States Tax Court · Mar 19, 2014

Memo. 2014-48 UNITED STATES TAX COURT JENNIFER LYNN FIELDS, Petitioner v. … Brown, Jr., for respondent.

Olive v. Comm'r

45 T.C.M. 1249 · United States Tax Court · Apr 11, 1983

On November 6, 1972, Special Agent Brown of the Intelligence Division contacted Mr. Olive. Mr. Olive referred Special Agent Brown to his attorney. The attorney provided Agent Brown with Mr. … Olive's books for 15 minutes so that Agent Brown could examine them. Agent Brown reviewed his analyses of the bank accounts with Mr. Olive and his attorney, and Mr.

Anderle v. Commissioner

10 T.C.M. 938 · United States Tax Court · Sep 28, 1951

Anderle v. Commissioner. Anderle v. Commissioner Docket No. 27579. United States Tax Court 1951 Tax Ct. Memo LEXIS 88 ; 10 T.C.M. (CCH) 938 ; T.C.M. (RIA) 51295 ; September 28, 1951 *88 Henry J. Anderle, pro se. … His first job was in a restaurant where he received approximately $30 per week, plus room and board. Later he settled in Pittsburgh and was employed as a member of a pole construction crew by the Bell Telephone Co.

Modern Computer Games, Inc. v. Commissioner

58 T.C.M. 23 · United States Tax Court · Sep 5, 1989

Barbados # 6 Ltd. v. Commissioner , 85 T.C. 900 , 904-905 (1985) . … Pearl, Tax Matters Partner v. Commissioner , supra .