Case law

Allen v. Comm'r

91 T.C.M. 673 · United States Tax Court · Jan 25, 2006

Petitioner was also a board member of Simpson Electric Co. (Simpson), an electric company owned and operated by the tribe. The tribe paid petitioner $8,000 in 2001 for attending Simpson board meetings. … V.

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.

Belshaw v. Commissioner

45 T.C.M. 1062 · United States Tax Court · Mar 23, 1983

BELSHAW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Belshaw v. Commissioner Docket No. 9706-80. United States Tax Court T.C. Memo 1983-157 ; 1983 Tax Ct. Memo LEXIS 626 ; 45 T.C.M. (CCH) 1062 ; T.C.M. … Pursuant to the first meeting of the board of trustees in 1977, all 100 units of beneficial interest in the trust were issued to petitioner.

Schwartz v. Commissioner

69 T.C. 877 · United States Tax Court · Mar 6, 1978

On January 18, 1968, Alpha and Thor, by their boards of directors, adopted plans for complete liquidation and dissolution during the succeeding 12-month period. … In Knipe v. Commissioner, T.C. Memo. 1965-131 , affd. per curiam sub nom. Equitable Publishing Co. 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.

EBERL'S CLAIM SERV. v. COMMISSIONER

77 T.C.M. 2336 · United States Tax Court · Jun 25, 1999

While we give little or no weight to the absence of formal board resolutions in closely held corporations, Levenson & Klein, Inc. v. Commissioner, 67 T.C. 694, 713-714 (1977); Reub Isaacs & Co. v. … See Pacific Grains, Inc. v. Commissioner, supra (corporate president was not underpaid in part because taxpayer's board did not state that some part of the payments were for his prior services); H&A Intl.

Uniroyal, Inc. v. Commissioner

65 T.C.M. 2690 · United States Tax Court · May 18, 1993

Co. , 338 U.S. 451 , 455 (1950) ; Gregory v. Helvering , 293 U.S. 465 , 469 (1935) ; United States v. … . * * * In Penrod v.

Walliser v. Commissioner

72 T.C. 433 · United States Tax Court · Jun 7, 1979

Heidt v. Commissioner, 274 F.2d 25, 27-28 (7th Cir. 1959), affg. T.C. Memo. 1959-31 ; Schmidlapp v. Commissioner, 96 F.2d 680, 681-682 (2d Cir. 1938); Christensen v. Commissioner, 17 T.C. 1456 (1952); Abraham v. … Petersburg Bank & Trust Co. 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

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.

Dobra v. Commissioner

111 T.C. 339 · United States Tax Court · Dec 29, 1998

See Williams v. … Cato v.

Jet Corp. v. Commissioner

10 T.C.M. 951 · United States Tax Court · Sep 24, 1951

Jet Corporation v. Commissioner. Jet Corp. v. Commissioner Docket No. 27189. United States Tax Court 1951 Tax Ct. Memo LEXIS 96 ; 10 T.C.M. (CCH) 951 ; T.C.M. (RIA) 51292 ; September 24, 1951 *96 Morton L. … The minutes of the April 6, 1933, meetings of petitioner's board of directors and of Manhattan's board of directors, referred to above, were signed in each instance by Elliott Sperber, as secretary, and those minutes in each

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 .

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.

Lombard v. Commissioner

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

Sec. 453(d); Bolton v. … Luman v.

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.

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.

Badger Materials, Inc. v. Commissioner

40 T.C. 725 · United States Tax Court · Jul 10, 1963

These three individuals also constituted the board of directors and were the principal stockholders. … Crosley Corporation v. United States, 229 F. 2d 376 (C.A. 6, 1956); Ross v. Commissioner, 169 F. 2d 488 (C.A. 1, 1948); Commissioner v. American Light & T.

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.

Hepinstall Steel Works v. Commissioner

3 T.C.M. 841 · United States Tax Court · Aug 9, 1944

Hepinstall Steel Works, Inc. v. Commissioner. Hepinstall Steel Works v. Commissioner Docket No. 3217. United States Tax Court 1944 Tax Ct. Memo LEXIS 142 ; 3 T.C.M. (CCH) 841 ; T.C.M. … Rogers, duly seconded, the *152 following resolution was unanimously adopted: "Be it resolved by the Board of Directors of Hepinstall Steel Works, Inc. that the salary of the president of this corporation for the calendar