Case law

Estate of Belcher v. Commissioner

83 T.C. 227 · United States Tax Court · Aug 16, 1984

In Commissioner v. … With the exception of one early decision of the Board of Tax Appeals, Estate of Dodge v.

Davenport v. Commissioner

70 T.C. 922 · United States Tax Court · Sep 14, 1978

The option decided on by Greenbelt’s board of directors required petitioner to personally endorse all loans made to Greenbelt. … In Marshall v.

Vincent v. Commissioner

19 T.C. 501 · United States Tax Court · Dec 24, 1952

Patsch, supra, and cases cited therein, principally Brown v. Helvering, 291 U. S. 193 ; Spencer, White & Prentis v. Commissioner, 144 F. 2d 45 ; Amalgamated Housing Corporation, 37 B. T. … Lucas v. Earl, 281 U. S. 111 ; Helvering v. Horst, 311 U. S. 112 ; Harrison v. Schaffner, 312 U. S. 579 .

Sparks Farm, Inc. v. Commissioner

56 T.C.M. 464 · United States Tax Court · Oct 12, 1988

Second, they argue, a quorum of the board of directors was never present at any of the board meetings when business was transacted. … XI, sec. 7 (1945); Kaiser v. Mouton, 631 S.W.2d 44 , 48-49 (Mo. App. 1981) . Sparks Farm, Inc.'s articles of incorporation stated that two directors would make up the board of directors. Mrs.

Vincent v. Commissioner

18 T.C. 339 · United States Tax Court · May 21, 1952

Rassenfoss v. Commissioner , 158 F. 2d 764 ; Hochschild v. Commissioner , 161 F. 2d 817 ; Kornhauser v. … Helvering v.

Banister v. Comm'r

109 T.C.M. 1047 · United States Tax Court · Jan 12, 2015

Petitioner’s certified public accountant’s license was revoked by the California Board of Accountancy in 2007 because of the conduct that led to his disbarment from practice before the IRS. … Miller v. Commissioner, 94 T.C. 316, 335 (1990); see Niedringhaus v. Commissioner, 99 T.C. at 212, 217-219; Chase v. Commissioner, T.C. Memo. 2004-142; Tonitis v. Commissioner, T.C. Memo. 2004-60; Madge v.

Wetterau Grocer Co. v. Commissioner

8 T.C.M. 434 · United States Tax Court · May 4, 1949

Wetterau Grocer Company, Inc. v. Commissioner. Wetterau Grocer Co. v. Commissioner Docket No. 16146. United States Tax Court 1949 Tax Ct. Memo LEXIS 200 ; 8 T.C.M. (CCH) 434 ; T.C.M. … In John Kelley Co. v. , the Supreme Court affirmed two Tax Court decisions on this question.

Peterson Machine Tool, Inc. v. Commissioner

79 T.C. 72 · United States Tax Court · Jul 14, 1982

V. … Major v. Commissioner, supra; Lazisky v. Commissioner, 72 T.C. 495 (1979); Lucas v. Commissioner, supra.

Guitar Trust Estate v. Commissioner

1 T.C.M. 312 · United States Tax Court · Dec 29, 1942

Guitar Trust Estate v. Commissioner. Guitar Trust Estate v. Commissioner Docket No. 107801. United States Tax Court 1942 Tax Ct. Memo LEXIS 6 ; 1 T.C.M. (CCH) 312 ; T.C.M. (RIA) 42688 ; 12/29/1942 *6 Percy W. … Morrissey v. Commissioner, 296 U.S. 344 , 356 ↩ .

Tirado v. Commissioner

74 T.C. 14 · United States Tax Court · Apr 10, 1980

A brown and white striped robe. m. A .22 caliber Winchester rifle. The items seized were considered by the officers as evidence of possession of, and trafficking in, drugs. … United States v. Golay, 502 F.2d at 184 . Cf. Andresen v. Maryland, supra; United States v. Thompson, supra; United States v. Robinson, 287 F. Supp. at 256 ; Gordon v.

Tombari v. Commissioner

35 T.C. 250 · United States Tax Court · Nov 10, 1960

Tombari, Petitioners, v. Commissioner of Internal Revenue, Respondent Tombari v. Commissioner Docket No. 76396 United States Tax Court 35 T.C. 250 ; 1960 U.S. Tax Ct. … The Board held that the 1921 collection was taxable in the ratio which the difference between the fair market value and the face bears to the face. This case was cited with approval in Victor B. Gilbert , 6 T.C. 10 .

Louise H. Edwards v. Commissioner

12 T.C.M. 1202 · United States Tax Court · Oct 28, 1953

Edwards, et al. 1 v. Commissioner. Louise H. Edwards v. Commissioner Docket Nos. 24909-24914. United States Tax Court 1953 Tax Ct. Memo LEXIS 79 ; 12 T.C.M. (CCH) 1202 ; T.C.M. (RIA) 53344 ; October 28, 1953 Chester H. … in accordance with such basis of classification as the board may deem just and proper.

Suttle v. Commissioner

37 T.C.M. 1638 · United States Tax Court · Oct 2, 1978

(Master), and during the years in issue he was its president, a member of its board of directors, and its salaried employee. … Dean v.

Frew v. Commissioner

8 T.C. 1240 · United States Tax Court · Jun 24, 1947

He then became chairman of the board of directors, which office he held at the time of his death. … Allen v. Trust Co. of Georgia , 326 U.S. 630 .

Affiliated Enterprises v. Commissioner

1 T.C.M. 551 · United States Tax Court · Feb 6, 1943

Affiliated Enterprises, Inc. v. Commissioner. Affiliated Enterprises v. Commissioner Docket No. 106834. United States Tax Court 1943 Tax Ct. Memo LEXIS 461 ; 1 T.C.M. (CCH) 551 ; T.C.M. … Petition was filed with the Board of Tax Appeals and in such proceedings it was determined () that petitioner did not derive 80 percent of its income from royalties and that it was not a personal holding company.

Zalk-Josephs Co. v. Commissioner

10 T.C.M. 662 · United States Tax Court · Jul 13, 1951

Zalk-Josephs Company v. Commissioner. Zalk-Josephs Co. v. Commissioner Docket No. 28247. United States Tax Court 1951 Tax Ct. Memo LEXIS 160 ; 10 T.C.M. (CCH) 662 ; T.C.M. (RIA) 51215 ; July 13, 1951 *160 Edward C. … Hazel Atlas Glass Co. v. Van Dyk & Reeves, Inc. (C.A. 2, 1925), . It is equally well settled that a stockholder has no right to the payment of dividends until they have been declared by the board of directors.

Erburu v. Commissioner

23 T.C. 820 · United States Tax Court · Jan 31, 1955

Erburu and Kathryn Erburu, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent Erburu v. Commissioner Docket No. 51137 United States Tax Court 23 T.C. 820 ; 1955 U.S. Tax Ct. … Commissioner v. Hirshon Trust, supra .

Continental Illinois Corp. v. Commissioner

58 T.C.M. 790 · United States Tax Court · Nov 28, 1989

See, e.g., Brown v. Helvering , 291 U.S. 193 (1934) ; Lucas v. American Code Co. , 280 U.S. 445 (1930) ; United States v. Anderson , 269 U.S. 422 (1926) . … Brown v. Helvering , 291 U.S. 193 , 201 (1934) . Thus, petitioner misplaces its reliance on Illinois Power Co. v. Commissioner , supra , and Franklin Life Insurance Co. v.

Estate of Mandels v. Commissioner

64 T.C. 61 · United States Tax Court · Apr 17, 1975

Brown, 52 T.C. 50, 66 (1969); sec. 25.2511-2(c), Gift Tax Regs.; Rev. Rul. 54-537, 1954- 2 C.B. 316 . … See Commissioner v.

Cohen v. Comm'r

46 T.C.M. 88 · United States Tax Court · May 9, 1983

See Nachison v. Commissioner, T.C. Memo. 1981-113 ; Whitten v. Commissioner, supra. … See, however, Considine v. Commissioner, 68 T.C. 52 (1977) ; Goodwin v. Commissioner, 73 T.C. 215 (1979) ; Considine v. United States, 645 F.2d 925 (Ct.Cl. 1981) ; Considine v.