Case law

Ulanoff v. Commissioner

77 T.C.M. 2034 · United States Tax Court · May 19, 1999

Freedman (Freedman), a certified public accountant and the named partner in Freedman & Co., was the president and chairman of the board of F&G. … Lindstrom also reported that various equipment companies, such as the Cumberland Engineering Division of John Brown Plastics Machinery, were willing to provide customized recycling programs to companies at a minimum cost

Eagle Office Equip. Co. v. Commissioner

5 T.C.M. 967 · United States Tax Court · Nov 13, 1946

Eagle Office Equipment Co., Inc. v. Commissioner. Eagle Office Equip. Co. v. Commissioner Docket No. 8739. United States Tax Court 1946 Tax Ct. Memo LEXIS 35 ; 5 T.C.M. (CCH) 967 ; T.C.M. … His salary was duly authorized by resolutions of the board of directors. The petitioner also paid him $38,061.33 as commissions on sales made by him during the taxable year.

Doyle v. Comm'r

2008 T.C. Summary Opinion 107 · United States Tax Court · Aug 21, 2008

Brown) had filed a chapter 12 bankruptcy petition in February 1999, which was dismissed in July 2000 at the debtors’ request. See Farmpro Servs., Inc. v. … Brown) would not have been able to acquire credit on such terms from an unrelated party in view of the bankruptcy filing. See Hall Paving Co. v.

Dietz v. Commissioner

62 T.C. 578 · United States Tax Court · Jul 31, 1974

Tbe Supreme Court in Bingler v. … In order for a residency program to be approved by the American Board of Psychiatry and Neurology and the Council on Medical Education of the American Medical Association, it had to meet the requirements of the Essentials

Charles W. Wright v. Commissioner

7 T.C.M. 738 · United States Tax Court · Sep 30, 1948

Wright v. Commissioner. Charles W. Wright v. Commissioner Docket No. 15189. United States Tax Court 1948 Tax Ct. Memo LEXIS 82 ; 7 T.C.M. (CCH) 738 ; T.C.M. (RIA) 48210 ; September 30, 1948 *82 William F. … as of January 31, 1935, a "reserve for pensions and gratuities" made up by the transfer of funds from the reserve for pension fund, from the *89 reserve for pensions, and from the reserve for contingencies; and that the board

Cox v. Commissioner

38 T.C.M. 136 · United States Tax Court · Jan 24, 1979

Commissioner v. Flowers, 326 U.S. 465 (1946) . … Compare Dowd v. Commissioner , 37 T.C. 399 (1961) , with Jones v. Commissioner , 54 T.C. 734 (1970) .

Estate of Prentice v. Commissioner

15 T.C.M. 14 · United States Tax Court · Jan 10, 1956

Macdonald and The New York Trust Company, Executors v. Commissioner. Estate of Prentice v. Commissioner Docket No. 44366. United States Tax Court T.C. Memo 1956-3 ; 1956 Tax Ct. Memo LEXIS 295 ; 15 T.C.M. … There were 15 members of the board in addition to the chairman and an honorary chairman.

Rittenhouse v. Commissioner

24 T.C.M. 1255 · United States Tax Court · Sep 13, 1965

Rittenhouse v. Commissioner. Rittenhouse v. Commissioner Docket No. 91695. United States Tax Court T.C. Memo 1965-245 ; 1965 Tax Ct. Memo LEXIS 85 ; 24 T.C.M. (CCH) 1255 ; T.C.M. (RIA) 65245 ; September 13, 1965 *85 1. … Mabrey thereupon went to Oregon and talked with Brown, who gave him certain information regarding petitioner's operation of the trucking business in Mount Morris.

Highland Merchandising Co. v. Commissioner

18 T.C. 737 · United States Tax Court · Jul 8, 1952

Highland Merchandising Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Highland Merchandising Co. v. Commissioner Docket No. 23882 United States Tax Court 18 T.C. 737 ; 1952 U.S. Tax Ct. … See Commissioner v. South Texas Lumber Co ., 333 U.S. 496 (1948) , rehearing denied 334 U.S. 813 (1948) .

Katz v. Commissioner

22 T.C.M. 769 · United States Tax Court · Jun 10, 1963

Seymour Katz and Rae Katz v. Commissioner. Katz v. Commissioner Docket No. 89514. United States Tax Court T.C. Memo 1963-160 ; 1963 Tax Ct. Memo LEXIS 185 ; 22 T.C.M. (CCH) 769 ; T.C.M. … This $520 *187 was all expended by Sarah during said year for the cost of board, lodging, clothing, medical and dental care, haircuts, drugs, cleaning of clothes, and other similar expenses for the support of Lawrence.

Scheidt v. Commissioner

63 T.C.M. 1726 · United States Tax Court · Jan 6, 1992

Allen v. Commissioner , supra at 34 . No single factor, nor the existence of even a majority of the factors, is controlling. Golanty v. Commissioner , supra at 426 ; Dunn v. … See, e.g., Davis v. Commissioner , 65 T.C. 1014 (1976) ( section 162 ); Nielsen v. Commissioner , 61 T.C. 311 (1973) (section 355); Davis v. Commissioner , 29 T.C. 878 (1958) (section 130); 5 Peterson Produce Co. v.

Loren S. Brumber v. Commissioner

11 T.C.M. 289 · United States Tax Court · Mar 31, 1952

Brumber v. Commissioner. Loren S. Brumber v. Commissioner Docket No. 31820. United States Tax Court 1952 Tax Ct. Memo LEXIS 277 ; 11 T.C.M. (CCH) 289 ; T.C.M. (RIA) 52087 ; March 31, 1952 Norman R. … Brown, Esq., and Edwin S. Phillips, Esq., Ellicott Square Bldg., Buffalo, N. Y., for the petitioner. Clay C. Holmes, Esq., for the respondent.

Gillespie v. Commissioner

35 T.C.M. 1181 · United States Tax Court · Aug 23, 1976

Sometime thereafter he mailed it to respondent. *139 Petitioner's return was assigned to Internal Revenue Agent Harold Brown (hereinafter Brown) for audit. … Interstate Transit Lines v. Commissioner, 319 U.S. 590 (1943) , Deputy v. DuPont, 308 U.S. 488 (1940) . Respondent's determination is presumptively correct, and petitioner has the burden of proving otherwise. Welch 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.

Laidiaw Transp. v. Commissioner

75 T.C.M. 2598 · United States Tax Court · Jun 30, 1998

LIIBV's September 12, 1988, Board Meeting On September 12, 1988, the members of LIIBV's board of directors discussed repayment by Transit, LWSI, and Tree of the advances from LIIBV. … Petitioners point out that the LIIBV board revised some of the documents that Haworth and Cairns had authored.

Callahan Realty Corp. v. Commissioner

1 T.C.M. 917 · United States Tax Court · Apr 19, 1943

Callahan Realty Corporation v. Commissioner. Callahan Realty Corp. v. Commissioner Docket No. 111796. United States Tax Court 1943 Tax Ct. Memo LEXIS 357 ; 1 T.C.M. (CCH) 917 ; T.C.M. … The question has been decided in accordance with the taxpayer's contention first by the Board of Tax Appeals in ; then again in ; and then by the Circuit Court of Appeals for the Eighth Circuit in affirming the latter decision

Enis v. Comm'r

2017 T.C. Memo. 222 · United States Tax Court · Nov 15, 2017

The board of directors consisted of the officers of the corporation--Dr. Ginsburg, Dr. Robinson, Mr. Burstein, and Mr. Enis. … The board of directors, however, met only once after executing the shareholders agreement.

Yoakum v. Commissioner

82 T.C. 128 · United States Tax Court · Jan 23, 1984

Brown, his Attorney and with the Defendant appearing by Floyd L. … In Gammill v.

Westreco, Inc. v. Commissioner

60 T.C.M. 824 · United States Tax Court · Sep 20, 1990

Goldsmith v. United States Board of Tax Appeals , 270 U.S. 117 (1926) , affg. 4 F.2d 422 (D.C. … The Supreme Court described the Board of Tax Appeals as being "quasi judicial in nature." Goldsmith v. United States Board of Tax Appeals , supra at 121.We pointed out in Burns, Stix Friedman & Co. v.

Estate of Henry v. Commissioner

69 T.C. 665 · United States Tax Court · Feb 6, 1978

Krause v. Commissioner, 56 T.C. 1242 (1971), appeal dismissed (nolle pros) (6th Cir. June 27, 1972); Estate of Sheaffer v. Commissioner, T.C. Memo. 1966-126 ; Estate of Morgan v. … However, this argument was rejected by the Board of Tax Appeals. The Commissioner in Turner v.