Case law

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.

Kleeden v. Commissioner

3 T.C.M. 1122 · United States Tax Court · Oct 25, 1944

Mark Kleeden v. Commissioner. Kleeden v. Commissioner Docket No. 1715. United States Tax Court 1944 Tax Ct. Memo LEXIS 70 ; 3 T.C.M. (CCH) 1122 ; T.C.M. (RIA) 44345 ; October 25, 1944 *70 A. E. … It further provided that the proposal be submitted to the board of directors at a special meeting and that petitioner and secretary of the company would endeavor to have it approved by the board.

Braunstein v. Commissioner

36 T.C. 22 · United States Tax Court · Apr 11, 1961

Spangler v. Commissioner, 278 F. 2d 665 , affirming 32 T.C. 782 ; Sydney v. Commissioner, 273 F. 2d 928 ; August v. Commissioner, 267 F. 2d 829 , affirming Elizabeth August, supra; Glickman v. … With respect to lumber, it was his testimony that they had anticipated they would need about 5 million board feet and the cost would be $100 per 1,000 board feet, whereas they were able to make their first purchases at $98.50

Clowe v. Commissioner

17 T.C. 1467 · United States Tax Court · Mar 12, 1952

Brooker v. Brooker , 130 Tex. 27 , 106 S. … Rust v. Rust , 211 S. W. 2d 262 , affd. 147 Tex. 181 , 214 S. W. 2d 462 ; Brooker v. Brooker, supra ; Boyd v. Frost Nat. Bank , 145 Tex. 206 , 196 S. W. 2d 497 , 503 .

Moore v. Commissioner

30 T.C. 1306 · United States Tax Court · Sep 30, 1958

C. 378 ; Phipps v. Commissioner, (C. A. 2) 54 F. 2d 469 ; and Home Co. v. Commissioner, (C. A. 10) 212 F. 2d 637 . In the last cited case the court stated: One may, of course, liquidate a capital asset. … Boomhower v. United States, 74 F. Supp. 997 .

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

Fannie Hirshon Trust U v. Commissioner

12 T.C.M. 364 · United States Tax Court · Apr 3, 1953

Fannie Hirshon Trust U/A Charles Hirshon, Walter Hirshon and Henry Siegbert, Trustees v. Commissioner. Fannie Hirshon Trust U/ v. Commissioner Docket No. 35013. United States Tax Court 1953 Tax Ct. … The dividend of shares of stock of Southern Production Company, Inc., was declared by the board of directors of Southern at a meeting of the board duly called and held on June 15, 1947, by resolutions reading as follows:

Automobile Club of St. Paul v. Commissioner

12 T.C. 1152 · United States Tax Court · Jun 28, 1949

Paul, Petitioner, v. Commissioner of Internal Revenue, Respondent Automobile Club of St. Paul v. Commissioner Docket No. 13318 United States Tax Court 12 T.C. 1152 ; 1949 U.S. Tax Ct. … During the war, it extended the facilities of its travel division to all service men and their families without cost and computed the official mileage upon which the ration boards granted gasoline to an applicant.

Scheffres v. Commissioner

28 T.C.M. 234 · United States Tax Court · Feb 26, 1969

Jerome and Myrtle Scheffres, et al. 1 v. Commissioner. Scheffres v. Commissioner Docket Nos. 4459-67-4461-67. United States Tax Court T.C. Memo 1969-41 ; 1969 Tax Ct. Memo LEXIS 255 ; 28 T.C.M. (CCH) 234 ; T.C.M. … Shillman v.

Vinnell v. Commissioner

52 T.C. 934 · United States Tax Court · Sep 11, 1969

Kerr v. Commissioner, supra ; United States v. Fewell , 255 F. 2d 496 (C.A. 5, 1958); Bradbury v. Commissioner , 298 F. 2d 111 (C.A. 1, 1962), affirming a Memorandum Opinion of this Court; Kessner v. … In Kerr v.

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.

Bennett v. Commissioner

12 T.C.M. 401 · United States Tax Court · Apr 16, 1953

Albert E. and Barbara Bennett v. Commissioner. Bennett v. Commissioner Docket No. 38342. United States Tax Court 1953 Tax Ct. Memo LEXIS 292 ; 12 T.C.M. (CCH) 401 ; T.C.M. (RIA) 53126 ; April 16, 1953 Eugene J. … Opinion MURDOCK, Judge: The only amounts for which the petitioner is now claiming deductions for travel expense under section 23 (a) (1) are those which it is agreed he spent for board and lodging in Albany during each year

Gill v. Commissioner

35 T.C. 1208 · United States Tax Court · Mar 31, 1961

That court in an opinion reported as Gill v. … Richfield Oil Corp. v. State Board, 329 U.S. 69 , and Market Street R. Co. v. Commission, 324 U.S. 548 . However, we feel that these cases are not in point.

Hiramanek v. Comm'r

102 T.C.M. 546 · United States Tax Court · Nov 28, 2011

Brown v. Commissioner, 51 T.C. 116, 119-120 (1968). … See Brown v. Commissioner, 51 T.C. at 120-121.

Croninger Packing Co. v. Commissioner

2 T.C.M. 1126 · United States Tax Court · Dec 15, 1943

Marshall, Receivers v. Commissioner. Croninger Packing Co. v. Commissioner Docket No. 407 P.T. United States Tax Court 1943 Tax Ct. Memo LEXIS 29 ; 2 T.C.M. (CCH) 1126 ; T.C.M. (RIA) 43509 ; December 15, 1943 *29 1. … vested in the Board of Review.

Multi-Pak Corp. v. Comm'r

99 T.C.M. 1567 · United States Tax Court · Jun 22, 2010

Scott Brown (Mr. Brown) prepared Multi-Pak’s Forms 1120 for 2000, 2001, 2002, and 2003. Mr. Brown is a certified public accountant at Roger A. Brown & Co. … Brown was not a competent professional with sufficient expertise to justify reliance. Mr. Brown testified that Mr.

Mathews v. Commissioner

20 T.C.M. 1565 · United States Tax Court · Oct 31, 1961

Mathews v. Commissioner. Mathews v. Commissioner Docket No. 84013. United States Tax Court T.C. Memo 1961-304 ; 1961 Tax Ct. Memo LEXIS 47 ; 20 T.C.M. (CCH) 1565 ; T.C.M. (RIA) 61304 ; October 31, 1961 *47 Martin L. … The rolling equipment of Packers Express which was sold to Garmhausen consisted of six 1954 Brown trailers, one Reo tractor, and one Trailmobile trailer.

Wren v. Commissioner

24 T.C.M. 290 · United States Tax Court · Mar 11, 1965

Clifford H. and Marjorie Cash Wren v. Commissioner. Wren v. Commissioner Docket No. 347-63. United States Tax Court T.C. Memo 1965-52 ; 1965 Tax Ct. Memo LEXIS 278 ; 24 T.C.M. (CCH) 290 ; T.C.M. … This the board agreed to do, whereupon petitioner's attorney discussed the matter with Oda's attorney.

Differential Steel Car Co. v. Comm'r

16 T.C. 413 · United States Tax Court · Feb 23, 1951

Even though we assume that the machinery and equipment constituted a contribution to capital within the ambit of Brown Shoe Co. v. Commissioner, 339 U. S. 583 , and Douglas Hotel Co., 14 T. … See George La Monte & Son v. Commissioner, supra, page 221.

Du Pont v. Commissioner

19 T.C. 377 · United States Tax Court · Dec 3, 1952

Rhett du Pont and Gertrude du Pont, Petitioners, v. Commissioner of Internal Revenue, Respondent Du Pont v. Commissioner Docket No. 35469 United States Tax Court 19 T.C. 377 ; 1952 U.S. Tax Ct. … Home Trust Co. v. Commissioner , 65 Fed. (2d) 532 ; Newark Milk & Cream Co. v. Commissioner , 34 Fed. (2d) 854 . Much the same can be said here as was said above in the Newburger case.