Case law

Patton v. Commissioner

49 T.C.M. 1068 · United States Tax Court · Mar 27, 1985

Nonetheless, Mississippi law did require the presence of the sheriff or a deputy to open the board's meetings. … The board met regularly twice a month, and had an undetermined number of special meetings.

Wiksell v. Commissioner

67 T.C.M. 2360 · United States Tax Court · Mar 9, 1994

Brown v. Commissioner , 51 T.C. 116 , 119 (1968) . … Brown v. Commissioner , 51 T.C. at 119 ; Stanley v. Commissioner , 45 T.C. 555 , 562 (1966) .

Piggy Bank Stations, Inc. v. Commissioner

47 T.C.M. 247 · United States Tax Court · Nov 3, 1983

Petitioners rely on Helvering v. Taylor, 293 U.S. 507 (1935) ; Meyer v. Commissioner, 46 T.C. 65 (1966) ; Nat Harrison Associates, Inc. v. Commissioner, 42 T.C. 601 (1964) ; and Doggett v. … A The funds that were given to Browne and Klink, that didn't pertain to the particular station, Browne and Klink intended to pay it, yes. Is that what you are asking?

Paul W. Thielking, O.D., P.C. v. Commissioner

53 T.C.M. 746 · United States Tax Court · May 4, 1987

Employee's compensation is to be reviewed by the Board of Directors annually. The above salary shall be continued until changed by action of the Board of Directors. At all times from the incorporation through 1980, Dr. … None of the minutes of the board of directors' meetings or annual stockholders' meetings indicate that the withdrawals which Dr.

Hogle v. Commissioner

7 T.C. 986 · United States Tax Court · Oct 17, 1946

The Board of Tax Appeals sustained the Commissioner under section 22 (a) and Helvering v. Clifford , 309 U.S. 331 . See 46 B. T. A. 122 . … Commissioner v. Prouty , 115 Fed. (2d) 331 ; Commissioner v. Beck's Estate , 129 Fed. (2d) 243 . The opinion of the Circuit Court in Hogle v.

Magruder v. Commissioner

57 T.C.M. 117 · United States Tax Court · Apr 17, 1989

See, for example, Dowell v. … Dowell v. United States, supra. *209 (Emphasis added.) In Berkley Machine Works & Foundry Co. v.

Estate of Thomas v. Commissioner

84 T.C. 412 · United States Tax Court · Mar 14, 1985

United States, supra at 574, 581 ; Commissioner v. Brown, 380 U.S. 563, 579-580 (1965) (Harlan, J., concurring); Rice’s Toyota World, Inc. v. … Detroit Consolidated Theatres, Inc. v. Commissioner, 133 F.2d 200 (6th Cir. 1942), affg. per curiam a Memorandum Opinion of the Board of Tax Appeals; Goodwin v.

Estate of Morgan v. Commissioner

52 T.C. 478 · United States Tax Court · Jun 18, 1969

Estate of Shirley Morgan, Deceased, Margaret Morgan, Administratrix, and Margaret Morgan, Petitioners v. Commissioner of Internal Revenue, Respondent; Clifford M. Pedersen and Thelma Pedersen, Petitioners v. … Commissioner of Internal Revenue, Respondent Estate of Morgan v. Commissioner Docket Nos. 2396-67, 2397-67 United States Tax Court 52 T.C. 478 ; 1969 U.S. Tax Ct.

Silling v. Commissioner

27 T.C. 701 · United States Tax Court · Jan 23, 1957

Silling, Petitioners, v. Commissioner of Internal Revenue, Respondent Silling v. Commissioner Docket No. 53539 United States Tax Court 27 T.C. 701 ; 1957 U.S. Tax Ct. … At the time of the sale, the partnership's tangible assets consisted of a few drafting boards and typewriters, *704 and it had no salable goodwill.

Reid v. Commissioner

50 T.C. 33 · United States Tax Court · Apr 9, 1968

Pickren v. United States, supra, at 600. See also Charles E. Kaltenbach v. United States, 66 Ct. Cl. 581 (1929). … See Pickren v. United States, supra at 600.

Barbara S. Kirkland v. Commissioner

4 T.C.M. 214 · United States Tax Court · Feb 12, 1945

Kirkland v. Commissioner. Betty Stoddard Horn v. Commissioner. Barbara S. Kirkland v. Commissioner Docket Nos. 103022, 103035. United States Tax Court 1945 Tax Ct. Memo LEXIS 294 ; 4 T.C.M. (CCH) 214 ; T.C.M. … The taxpayers petitioned the United States Board of Tax Appeals for a review of his determination. In a Memorandum Opinion entered November 19, 1942, the Commissioner's contention was sustained.

Petersen v. Commissioner

36 T.C.M. 11 · United States Tax Court · Jan 11, 1977

PETERSEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Petersen v. Commissioner Docket No. 187-76. United States Tax Court T.C. Memo 1977-4 ; 1977 Tax Ct. Memo LEXIS 439 ; 36 T.C.M. (CCH) 11 ; T.C.M. … See Rogers v. United States, 340 U.S. 367 , 374 (1951) ; Brown v. Walker, 161 U.S. 591 , 599-600 (1896) ; Boren v. Tucker, 239 F. 2d 767 , 772 (9th Cir. 1956) ; E. Jan Roberts, 62 T.C. 834 , 838 (1974) .

Forkan v. Commissioner

36 T.C.M. 798 · United States Tax Court · Jun 23, 1977

As this Court stated in DeJong v. … Commissioner , 61 T.C. 634 (1974) (land dedicated in exchange for subdivision concession from local planning board); Grinslade v.

September Partners, Ltd. v. Commissioner

58 T.C.M. 1244 · United States Tax Court · Jan 18, 1990

BROWN, WILLIAM J. CUNNEEN, ARTHUR W. LEIGHTON, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent September Partners, Ltd. v. … Computer Programs Lambda, Ltd. v.

Scherer v. Commissioner

3 T.C. 776 · United States Tax Court · May 10, 1944

In Commissioner v. … Commissioner, 131 Fed. (2d) 323; Schroder v. Commissioner, 134 Fed. (2d) 346; Earp v. Jones, 131 Fed, (2d) 292; Tinkoff v. Commissioner, 120 Fed. (2d) 564, affirming Board of Tax Appeals memorandum opinion; Thomas M.

Leith v. Commissioner

47 T.C.M. 255 · United States Tax Court · Nov 8, 1983

Sec. 6213; Brown v. Commissioner, 78 T.C. 215 , 220 (1982) ; Rule 13(c), Tax Court Rules of Practice and Procedure. … See Brown v. Commissioner, supra at 220 . *120 In general section 7502 treats a petition as timely filed if it is timely "mailed."

Barber-Greene Americas, Inc. v. Commissioner

35 T.C. 365 · United States Tax Court · Nov 30, 1960

See also United States v. Cumberland Public Service Co., 338 U.S. 451 (1950). … It became necessary for the Board to examine the surrounding facts to determine that intent.

Santa Fe Pacific Gold Company and Subsidiaries, By and Through Its Successor in Interest Newmont USA Limited v. Commissioner

132 T.C. No. 12 · United States Tax Court · Apr 27, 2009

Deductibility v. Capitalization.....................33 A. INDOPCO, Inc. v. Commissioner...................36 B. Victory Mkts., Inc. & Subs. v. Commissioner.....37 C. United States v. … INDOPCO, Inc. v. Commissioner, supra at 83; Commissioner v. Tellier, supra; Commissioner v. Heininger, 320 U.S. 467 (1943); see also Locke Manufacturing Cos. v. United States, 237 F. Supp. 80 (D.

Acacio v. Commissioner

28 T.C.M. 1495 · United States Tax Court · Dec 29, 1969

Acacio v. Commissioner. Acacio v. Commissioner Docket No. 1313-69 "SC". United States Tax Court T.C. Memo 1969-290 ; 1969 Tax Ct. Memo LEXIS 4 ; 28 T.C.M. (CCH) 1495 ; T.C.M. (RIA) 69290 ; December 29, 1969 . … Of the $1,508 paid for Ronald Bruce's support, petitioner paid $393 directly for doctor bills, clothes, and room and board for the month of December.

Peters v. Commissioner

41 T.C.M. 955 · United States Tax Court · Feb 24, 1981

In 1953, petitioner and Elwanda purchased a house located at 4041 Brown Street, Flint, Michigan, for $ 8,000. … Petitioner and his wife resided at 4041 Brown Street until 1963.