Case law

Gray v. Commissioner

140 T.C. 163 · United States Tax Court · Apr 25, 2013

The same 30-day period to appeal the determination applies across the board. See sec. 6330(d). … Freije v.

Halliburton Co. v. Commissioner

93 T.C. 758 · United States Tax Court · Dec 26, 1989

Although its facilities were nationalized, petitioner designated Iranian representatives to attend the Doreen/IMCO shareholders’ and board of directors’ meetings held in Tehran in September 1979. … Group v.

Std. Brass & Mfg. Co. v. Comm'r

20 T.C. 371 · United States Tax Court · May 18, 1953

Standard Brass & Manufacturing Co., Petitioner, v. Commissioner of Internal Revenue, Respondent Std. Brass & Mfg. Co. v. Comm'r Docket No. 35644 United States Tax Court 1953 U.S. Tax Ct. LEXIS 159 ; 97 U.S.P.Q. … Buckingham advised him that it would be necessary to present the matter to the board of directors of the corporation for consideration and that it would consent to a reduction of the rates.

McIntosh v. Commissioner

85 T.C. 31 · United States Tax Court · Jul 16, 1985

In Cook v. … In Boucher v.

Clark v. Commissioner

45 T.C.M. 144 · United States Tax Court · Nov 18, 1982

CLARK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JO ANN CLARK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Clark v. Commissioner Docket Nos. 5810-79, 19122-80. … Susan *83 worked part-time during that year, but she made no contribution toward her room or board or to the support of John or David.

Klamath Medical Service Bureau v. Commissioner

29 T.C. 339 · United States Tax Court · Nov 22, 1957

That petitioner intended to distribute earnings under the guise of payment for services rendered seems clear to us in the light of the testimony of the president of petitioner’s board of directors during the years at issue … Co. v. Commissioner, (C. A. 4) 149 F. 2d 421 .

Fisher Cos. v. Commissioner

84 T.C. 1319 · United States Tax Court · Jun 24, 1985

See Brown v. Commissioner, 22 T.C. 147, 150 (1954), affd. 220 F.2d 12 (7th Cir. 1955). … As we stated in Brown v.

Union Inv. Co. v. Commissioner

21 T.C. 659 · United States Tax Court · Jan 29, 1954

See Commissioner v. Heininger . 2 See also Lilly v. Commissioner , 343 U.S. 90 . … Citron-Byer Co. v. Commissioner, 21 B. T. A. 308 ; Headley v. Commissioner, 37 B. T. A. 738 . Cf. Helvering v. Superior Wines & Liquors, supra , Note 3.

Lombard v. Commissioner

67 T.C.M. 2636 · United States Tax Court · Apr 13, 1994

Sec. 453(d); Bolton v. … Luman v.

Scott Bros. Hosiery Mills v. Commissioner

1 T.C.M. 632 · United States Tax Court · Feb 19, 1943

Scott Brothers Hosiery Mills, Inc. v. Commissioner. Scott Bros. Hosiery Mills v. Commissioner Docket No. 110918. United States Tax Court 1943 Tax Ct. Memo LEXIS 440 ; 1 T.C.M. (CCH) 632 ; T.C.M. … This same petitioner asked the Board to redetermine a deficiency for 1928.

Crowley, Milner & Co. v. Commissioner

76 T.C. 1030 · United States Tax Court · Jun 17, 1981

See Leslie Co. v. Commissioner, 539 F.2d at 949 . In Leslie Co. v. … Jordan Marsh Co. v. Commissioner, 269 F.2d at 455 ; Biggs v. Commissioner, 69 T.C. 905, 913 (1978), affd. 632 F.2d 1171 (5th Cir. 1980). In Koch v.

TOMEN POWER CORP. v. COMMISSIONER OF INTERNAL REVENUE

2000 U.S. Tax Ct. LEXIS 98 · United States Tax Court · Jul 12, 2000

Toyo Construction Company and Subsidiaries, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. TOMEN POWER CORP. v. COMMISSIONER OF INTERNAL REVENUE 12955-96 United States Tax Court 2000 U.S. Tax Ct. … BROWN Chief Counsel Internal Revenue Service

Black v. Commissioner

5 T.C. 759 · United States Tax Court · Sep 19, 1945

See Carrier v. Carrier, 226 N. Y. 114 ; 123 N. E. 135 , cited in Hall v. Commissioner, supra. … As stated by the Supreme Court in Helvering v.

ESTATE OF H.A. TRUE v. COMMISSIONER

82 T.C.M. 27 · United States Tax Court · Jul 6, 2001

True-Brown Partnerships Dave True and Doug Brown jointly pursued other business ventures (collectively, True-Brown partnerships). … April 20, 2001); Estate of Ford v. Commissioner, T.C. Memo. 1993-580, affd. 53 F.3d 924 (8th Cir. 1995); Brown v. Commissioner, T.C. Memo. 1966-92; Estate of Cookson v. Commissioner, T.C. Memo. 1965-319.

North Shore Bus Co. v. Commissioner

1 T.C.M. 493 · United States Tax Court · Jan 27, 1943

North Shore Bus Company, Inc. v. Commissioner. North Shore Bus Co. v. Commissioner Docket No. 108391. United States Tax Court 1943 Tax Ct. Memo LEXIS 490 ; 1 T.C.M. (CCH) 493 ; T.C.M. … The Board held that since the year 1934 was still open the amount refunded in 1939 should be restored to 1934 income.

Fleischman v. Commissioner

45 T.C. 439 · United States Tax Court · Feb 21, 1966

Kornhauser v. United States, 276 U.S. 145 (1928). … Higgins v. Commissioner, 312 U.S. 212 (1941).

Girdler v. Commissioner

2 T.C.M. 482 · United States Tax Court · Jul 20, 1943

Girdler v. Commissioner. Norris J. Clarke v. Commissioner. Charles M. White and Helen B. White v. Commissioner. R. J. Wysor v. Commissioner. Girdler v. Commissioner Docket Nos. 262, 263, 264, 265. … Girdler was chairman of the board; Wysor was president; White was vice-president in charge of operations, and Clarke was vice-president in charge of sales. Each was a shareholder and Girdler and Wysor were directors.

Morgan v. Commissioner

50 T.C.M. 114 · United States Tax Court · Jun 12, 1985

The Board of Directors of the local chapter consisted of petitioner, her friend Sandra Anderson and Sandra's son, David Ely. … The Board of Directors met once a month. All meetings took place at 2427 West Lake, Phoenix, Arizona, a residence owned jointly by petitioner and Anderson.

Steven Yari v. Commissioner

143 T.C. No. 7 · United States Tax Court · Sep 15, 2014

See Callahan v. Commissioner, 130 T.C. … FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 133 (2000) (quoting Davis v. Mich. Dep’t of Treasury, 489 U.S. 803, 809 (1989)).

Hansen v. Commissioner

11 T.C.M. 486 · United States Tax Court · May 15, 1952

Betty Hansen et al. 1 v. Commissioner. * Hansen v. Commissioner Docket Nos. 29419, 29420, 29421. United States Tax Court 1952 Tax Ct. Memo LEXIS 220 ; 11 T.C.M. (CCH) 486 ; T.C.M. (RIA) 52142 ; May 15, 1952 Henry W. … Also, Oscar had virtually absolute control over the board of directors of the corporation and dominated its policies.