Case law

Jenkins v. Commissioner

70 T.C.M. 1423 · United States Tax Court · Nov 28, 1995

Petitioner obtained these figures using his brown books. … Grosshandler v. Commissioner, supra at 20. Petitioner's brown books were inadequate. He was unable to use his brown books or other records to substantiate any of petitioners' expenses.

Roach v. Commissioner

4 T.C. 1255 · United States Tax Court · Apr 30, 1945

Roach, Petitioner, v. Commissioner of Internal Revenue, Respondent Roach v. Commissioner Docket No. 4305 United States Tax Court 4 T.C. 1255 ; 1945 U.S. Tax Ct. … A complete liquidation within the meaning of the Revenue Act of 1936 was found by a District Court of Pennsylvania in McCune 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

Harvey Amusement Co. v. Commissioner

1 T.C.M. 231 · United States Tax Court · Dec 17, 1942

BAV Minutes of a meeting of the board of directors of Avenal, consisting of H. V. Harvey, R. W. Harvey and B. A. … As appears from the minutes of a meeting of the board of directors of Avenal, consisting of four members, held on July 5, 1938, H. V.

McGuire v. Commissioner

32 T.C.M. 222 · United States Tax Court · Feb 27, 1973

James v. United States, 366 U.S. 213 (1961) ; Rutkin v. United States, 343 U.S. 130 (1952) . … Plunkett v. Commissioner, 465 F. 2d 299 (C.A. 7, 1972), affirming a Memorandum Opinion of this Court: Moore v. United 37 States, 360 F. 2d 353 (C.A. 4, 1966); Amos v.

Estate of Clarke v. Commissioner

54 T.C. 1149 · United States Tax Court · May 27, 1970

Brown, 51 T.C. 116, 120-121 (1968); Hazel Stanley, 45 T.C. 555, 560-561 (1966) (dictum), or fraud, Scudder v. … The first, Scudder v.

Huff v. Commissioner

138 T.C. 258 · United States Tax Court · Mar 19, 2012

HUFF, PETITIONER v. … Price, Ladd Christman Brown, Jr., and Justin L. Campolieta, for respondent.

Rugby Prods. v. Commissioner

100 T.C. 531 · United States Tax Court · Jun 14, 1993

Castner Garage, Ltd. v. Commissioner, 43 B.T.A. 1, 5 (1940); cf. Peoples Finance & Thrift Co. v. … Petitioner cites Bass v. John Hancock Mut. Life Ins.

Benedek v. Commissoner

50 T.C. 732 · United States Tax Court · Aug 12, 1968

All but Nathan Neitlich were members of the board of directors. In 1947, the New York Water Service Corp. (Water Corp.), a regulated public utility, owned a substantial amount of property in Brooklyn, N.Y. … Commissioner, supra; Payne v. Commissioner, 268 F. 2d 617 (C.A. 5, 1959), affirming 30 T.C. 1044 (1958); Max Mintz, supra.

Hansen v. Commissioner

11 T.C.M. 781 · United States Tax Court · Jul 28, 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 132 ; 11 T.C.M. (CCH) 781 ; T.C.M. (RIA) 52236 ; July 28, 1952 Henry W. … Hansen v. Bear Film Co., et al. Case No. 296,867, are also incorporated herein by this reference. In October, 1946, the petitioners Betty Hansen and Carl L.

United-American Sav. & Loan Asso. v. Commissioner

27 T.C.M. 421 · United States Tax Court · May 20, 1968

United-American Savings & Loan Association of Pittsburgh, Pa. v. Commissioner. United-American Sav. & Loan Asso. v. Commissioner Docket No. 6597-66. United States Tax Court T.C. Memo 1968-91 ; 1968 Tax Ct. … Any insured state-chartered institution may by resolution of its board of directors or by other appropriate corporate action designate as its Federal insurance reserve account any reserve account which under the provisions

Zipp v. Commissioner

28 T.C. 314 · United States Tax Court · Apr 30, 1957

Wall v. United States, 164 F. 2d 462 . … Paramount-Richards Theatres v. Commissioner, 153 F. 2d 602, 604 ; Byers v. Commissioner, 199 F. 2d 273, 275 .

Hewett v. Commissioner

47 T.C. 483 · United States Tax Court · Feb 13, 1967

Brown , for the respondent. Drennen , Judge . DRENNEN *483 Respondent determined a deficiency in petitioners' income tax for the taxable year 1962 in the amount of $ 19,441.53. … Trust of Bingham v.

Buchholz Mortuaries, Inc. v. Commissioner

59 T.C.M. 746 · United States Tax Court · May 30, 1990

BUCHHOLZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Buchholz Mortuaries, Inc. v. Commissioner Docket Nos. 13962-88, 14064-88 United States Tax Court T.C. Memo 1990-269 ; 1990 Tax Ct. … On October 9, 1981, the board of directors of Mortuaries adopted a resolution approving a tender offer by the Buchholzes.

Green v. Commissioner

1 T.C.M. 297 · United States Tax Court · Dec 23, 1942

Heatley Green v. Commissioner. Charles F. Whitman v. Commissioner. Green v. Commissioner Docket Nos. 109529, 109530. United States Tax Court 1942 Tax Ct. Memo LEXIS 16 ; 1 T.C.M. (CCH) 297 ; T.C.M. … On December 28, 1939, pursuant to resolutions passed at a special meeting of the board of directors of the old company 1 the forms of conveyance of the property to Bangor and the new company were approved and the officers

Carol Diane Gray v. Commissioner

140 T.C. No. 9 · United States Tax Court · Apr 25, 2013

The same 30-day period to appeal the determination applies across the board. See sec. 6330(d). Some of the arguments petitioner advances in her motion warrant further discussion. … See Greene-Thapedi v.

Serri v. Commissioner

23 T.C.M. 1319 · United States Tax Court · Aug 18, 1964

Serri v. Commissioner. Serri v. Commissioner Docket No. 91969 United States Tax Court T.C. Memo 1964-219 ; 1964 Tax Ct. Memo LEXIS 120 ; 23 T.C.M. (CCH) 1319 ; T.C.M. (RIA) 64219 ; August 18, 1964 *120 1. … Northwestern Bank 5's 52,000 22,000 Red seal 1928 10,000 Green seal 28-34 14,000 Brown S. 1929 6,000 Blue S. 1934 10's 40,000 20,000 Brown S. 1929 9,000 Blue S. 33-34 11,000 Green S. 28-34 20's 13,000 9,000 Brown S. 1929

Johnson v. Commissioner

37 T.C.M. 418 · United States Tax Court · Mar 6, 1978

Bailey v. Commissioner, 60 T.C. 447 , 452-453 . Compare Hembree v. United States, 464 F. 2d 1262 , 1264-1265 (C.A. 4); Weinberg v. Commissioner, 64 T.C. 771 , 778 ; Fisher v. … Bingler v. Johnson, supra, 394 U.S. at 757 -758 ; Buhr v. Commissioner, F. 2d , 77-2 U.S.T.C. par. 9633 (C.A. 7); Ussery v. Commissioner, 296 F. 2d 582 , 586-587 *436 (C.A. 5); MacDonald v.

Blueberry Land Co. v. Commissioner

42 T.C. 1137 · United States Tax Court · Sep 30, 1964

The answer to the question before us is controlled by the principles enunciated by the Supreme Court in Gregory v. Helvering, supra, and Commissioner v. Court Holding Co., supra. In Gregory v. … In Commissioner v.

Feistel v. Commissioner

4 T.C.M. 114 · United States Tax Court · Jan 27, 1945

Held, following Earp v. Jones, 131 Fed. (2d) 292 and Mead v. Commissioner, 131 Fed. (2d) 323 , the entire net income of the partnership is taxable to petitioner. Humphreys v. … The court its opinion in that case pointed out the basis on which the Board of Tax Appeals had held that the income of the partnership was all taxable to the husbands in the following language: The opinion of the Board stated