Case law

Rocchio v. Comm'r

2011 T.C. Summary Opinion 58 · United States Tax Court · May 11, 2011

Brown, Jr., for respondent. … In Commissioner v.

Winston v. Commissioner

15 T.C.M. 477 · United States Tax Court · Apr 18, 1956

(C.A. 5) 148 Fed. (2d) 570 ; Brown v. Commissioner (C.A. 5), 143 Fed. (2d) 468 , affirming a decision of this Court [ 2 TCM 714 ,] ; Ehrman v. … Brown v. Commissioner, supra ; Welch v. Solomon (C.A. 9), 99 Fed. (2d) 41 ; Snell v. Commissioner (C.A. 5), 97 Fed. (2d) 891 , affirming a decision of this Court; and Mauldin v. Commissioner, supra.

Anderson v. Commissioner

23 T.C.M. 1170 · United States Tax Court · Jul 15, 1964

Subsequently, petitioner met George Brown. He discussed with Brown the possibility of Brown's firm purchasing the property. Brown referred him to his partner Walter Keusder, Sr. … Commissioner v. Culbertson, 337 U.S. 733 (1949) ; and United States v. Kintner, 216 F. 2d 418 (C.A. 9, 1954).

Robert R. Doggart

United States Tax Court · Jul 27, 2023

Black v. Commissioner, T.C. Memo. 2014-27, at *8–9; Brown v. Commissioner, T.C. Memo. 2011 83, slip op. at 10–12, aff’d, 693 F.3d 765 (7th Cir. 2012); Sanders v. Commissioner, T.C. … Brown v. Commissioner, 693 F.3d at 768. As physical receipt of cash does not dictate taxability, the initial disbursement of the loans was not taxable.

Feldman v. Commissioner

51 T.C.M. 1412 · United States Tax Court · Jul 14, 1986

Engdahl v. Commissioner, 72 T.C. 659 , 665 (1979) . Whether it does or not depends on whether making a profit was the primary purpose of the venture. Engdahl v. Commissioner, supra at 666 ; Dunn v. … See Golanty v.

John B. Stetson Co. v. Commissioner

23 T.C.M. 876 · United States Tax Court · May 25, 1964

Stetson Company v. Commissioner. John B. Stetson Co. v. Commissioner Docket No. 2859-62. United States Tax Court T.C. Memo 1964-146 ; 1964 Tax Ct. Memo LEXIS 190 ; 23 T.C.M. (CCH) 876 ; T.C.M. … See Hawaiian Trust Company, Limited, v. United States, (C.A. 9) 291 F. 2d 761 ; and Berland's Inc. of South Bend [ Dec. 18,057 ], 16 T.C. 182 .

Hirsch v. Commissioner

51 T.C. 121 · United States Tax Court · Oct 23, 1968

Since October 1964 he has been president and chairman of the board of directors of Pacific. … Sloane v. Commissioner, 188 F. 2d 254 (C.A. 6, 1951); Frank Hodous, 14 T.C. 1301 (1950); Craig M. Smith, 33 T.C. 465 (1959), affirmed on this point 313 F. 2d 724 (C.A. 8, 1963); Pounds v.

Sherwood Swan & Co. v. Commissioner

42 T.C. 299 · United States Tax Court · Apr 30, 1964

At all times material hereto, he has also been a member of the company’s board of directors. On January 31,1943, the company and Frank G. … long as said trust remains in existence * * * Even though there is authority to the effect that a qualified profit-sharing trust need not contain a fixed formula of contribution to its corpus, Lincoln Electric Co., Etc. v.

Moore v. Commissioner

3 T.C.M. 579 · United States Tax Court · Jun 14, 1944

George D. and Marie V. Moore v. Commissioner. Moore v. Commissioner Docket No. 3447. United States Tax Court 1944 Tax Ct. Memo LEXIS 202 ; 3 T.C.M. (CCH) 579 ; T.C.M. (RIA) 44212 ; June 14, 1944 *202 George D. … Sometime in or about October 1941, the stock of the company was purchased by one of the Aetna group and a new board of directors was chosen and the *203 management changed.

J. Albert & Sons v. Commissioner

10 T.C.M. 86 · United States Tax Court · Jan 26, 1951

Albert & Sons, Inc. v. Commissioner. J. Albert & Sons v. Commissioner Docket No. 25024. United States Tax Court 1951 Tax Ct. Memo LEXIS 339 ; 10 T.C.M. (CCH) 86 ; T.C.M. … We are next concerned with the deductibility of the $1,500 additional compensation paid to each Joseph and Philip Albert, pursuant to the December 27, 1945, resolution of the petitioner's board of directors.

Sagner v. Commissioner

12 T.C.M. 1355 · United States Tax Court · Nov 30, 1953

Stanley Sagner v. Commissioner. Sagner v. Commissioner Docket No. 37089. United States Tax Court 1953 Tax Ct. Memo LEXIS 48 ; 12 T.C.M. (CCH) 1355 ; T.C.M. … Following such decision, the board of directors of Treff, Inc., on July 8, 1946, after full discussions, unanimously adopted a resolution reading as follows: *54 "RESOLVED, that the Board of Directors of Treff Inc., by unanimous

Sarfert Hosiery Mills v. Commissioner

6 T.C.M. 1208 · United States Tax Court · Nov 13, 1947

Sarfert Hosiery Mills, Inc. v. Commissioner. Sarfert Hosiery Mills v. Commissioner Docket No. 9512. United States Tax Court 1947 Tax Ct. Memo LEXIS 37 ; 6 T.C.M. (CCH) 1208 ; T.C.M. … These three officers constituted its board of directors.

Neville Coke & Chemical Co. v. Commissioner

3 T.C. 113 · United States Tax Court · Jan 25, 1944

See Eckert v. Burnet , 283 U.S. 140 . We think that petitioner realized a gain represented by the value of the stock received. Cf. Commissioner v. … National Bank of Commerce of San Antonio , 112 Fed. (2d) 946 ; Bingham v. Commissioner , 105 Fed. (2d) 971 ; Commissioner v.

Patrick J. Wachter & Louise M. Wachter v. Commissioner

142 T.C. No. 7 · United States Tax Court · Mar 11, 2014

Co. v. Commissioner, 95 T.C. 156, 161 (1990) (quoting United States v. … In Irby v.

Woodward v. Commissioner

49 T.C. 377 · United States Tax Court · Jan 23, 1968

See Helvering v. … United States, supra, which, is strongly relied upon by respondent, a majority of the stockholders of an Oklahoma corporation, in accordance with the provisions of an Oklahoma statute, authorized the board of directors to

Shannon v. Commissioner

29 T.C. 702 · United States Tax Court · Jan 28, 1958

Brown, 27 T. C.27 (1956). … See Sun Properties v. United States, supra; Warren H. Brown, supra. C.

Bernard G. Brennan Co., an Illinois corp. v. Commissioner

6 T.C.M. 195 · United States Tax Court · Feb 21, 1947

Brown, Esq., and W. Robert Brown, Esq., for the petitioner. Raymond F. Brown, Esq., and Irene F. Scott, Esq., for the respondent. … If Commissioner v.

Schiers v. Commissioner

35 T.C.M. 149 · United States Tax Court · Feb 10, 1976

She had brought it home in a brown suitcase or satchel, and told him that the banker had died. … Hort v. Commissioner, 313 U.S. 28 , 32-33 ; Marks v.

Nadeau v. Commissioner

8 T.C.M. 658 · United States Tax Court · Jul 6, 1949

Blanche Nadeau v. Commissioner. Nadeau v. Commissioner Docket No. 17649. United States Tax Court 1949 Tax Ct. Memo LEXIS 129 ; 8 T.C.M. (CCH) 658 ; T.C.M. (RIA) 49177 ; July 6, 1949 M. Blanche Nadeau, pro se. Melvin L. … The record fails to show that the amounts expended for board and lodging were in any sense incurred for the production or collection of *135 income from the petitioner's securities or for the management, conservation, or

Messenger Publ. Co. v. Commissioner

6 T.C.M. 988 · United States Tax Court · Aug 26, 1947

Messenger Publishing Company v. Commissioner. Messenger Publ. Co. v. Commissioner Docket No. 11420. United States Tax Court 1947 Tax Ct. Memo LEXIS 101 ; 6 T.C.M. (CCH) 988 ; T.C.M. … One of petitioner's officers and directors thought that McBride was a member of that Board.