Case law

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.

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.

Unvert v. Commissioner

72 T.C. 807 · United States Tax Court · Aug 8, 1979

Walters, a founder and the chairman of the board of U.S. Financial Corp., and David G. Leaverton (Leaverton), house counsel. … See also Hess v. United States, 210 Ct.

G. & W. H. Corson, Inc. v. Commissioner

12 T.C.M. 753 · United States Tax Court · Jun 30, 1953

Corson, Inc. v. Commissioner. G. & W. H. Corson, Inc. v. Commissioner Docket No. 32243. United States Tax Court 1953 Tax Ct. Memo LEXIS 184 ; 12 T.C.M. (CCH) 753 ; T.C.M. (RIA) 53242 ; June 30, 1953 *184 Richard L. … Only the *185 common stock had voting rights and was to be issued for such consideration as fixed and determined from time to time by the board of directors.

Russell v. Commissioner

5 T.C. 974 · United States Tax Court · Oct 24, 1945

C. 921 , and Phipps v. Commissioner, 137 Fed. (2d) 141. … The resolution adopted by the board of directors December 29, 1941, voting a bonus of $200,000 to four of the employees of the company, of whom petitioner was one, had provided: “and payable to them in such form, manner and

Western Mgmt. v. Comm'r

85 T.C.M. 1442 · United States Tax Court · Jun 3, 2003

In 1981, petitioner’s board of directors voted to pay Kovacevich $28,000 in 1982 and $60,000, annually, thereafter. … V.

West v. Commissioner

3 T.C. 431 · United States Tax Court · Mar 10, 1944

Cullen v. Commissioner, supra; West Production Co. v. Commissioner, supra; McLean v. Commissioner, 120 Fed. (2d) 942; Commissioner v. Fleming. 82 Fed. (2d) 324; Palmer v. Bender, 287 U. S. 551 ; and Burnet v. … See also Hogan v. Commissioner (C. C. A., 5th Cir.), 141 Fed. (2d) 92. Nor is the use of apt words of conveyance in the deed controlling, as contended by petitioners. It appears from the opinion of the Board in H. R.

Jamvold v. Commissioner

11 T.C. 122 · United States Tax Court · Aug 5, 1948

Jamvold, Petitioners, v. Commissioner of Internal Revenue, Respondent Jamvold v. Commissioner Docket No. 13490 United States Tax Court 11 T.C. 122 ; 1948 U.S. Tax Ct. … During that period he roomed and boarded at the house occupied by his future wife, the petitioner Ruth.

Benbow v. Commissioner

12 T.C.M. 380 · United States Tax Court · Apr 9, 1953

Everett Benbow v. Commissioner. Benbow v. Commissioner Docket No. 38468. United States Tax Court 1953 Tax Ct. Memo LEXIS 302 ; 12 T.C.M. (CCH) 380 ; T.C.M. (RIA) 53117 ; April 9, 1953 Cyrus B. … Bechtel, under its agreement, provided petitioner with board and lodging at its "jobsite" dormitories, or tent, or camp, or barracks.

Zehnder v. Commissioner

32 T.C.M. 1189 · United States Tax Court · Nov 21, 1973

Proskey, 51 T.C. 918 (1969) . *45 In Bingler v. … Likewise, in Rundell v.

Harris v. Commissioner

11 T.C.M. 895 · United States Tax Court · Aug 25, 1952

Harris v. Commissioner. Harris v. Commissioner Docket No. 31089. United States Tax Court 1952 Tax Ct. Memo LEXIS 103 ; 11 T.C.M. (CCH) 895 ; T.C.M. (RIA) 52258 ; August 25, 1952 *103 Junius H. … The wife's right in the community became a separate equal and co-existing right, Rawlings v.

Keller v. Comm'r

91 T.C.M. 1292 · United States Tax Court · Jun 22, 2006

On July 31, 1995, petitioner signed a “Share-Crop Board Agreement” (board agreement). The board agreement provided that  - 9 - W.J. … Hoyt Sons Management Co. would breed and board all of petitioner’s cattle. Petitioner did not keep a copy of the board agreement for his records.

Take v. Commissioner

50 T.C.M. 600 · United States Tax Court · Aug 5, 1985

OPINION In Take v. … We said in Take v.

Caspers v. Commissioner

44 T.C. 411 · United States Tax Court · Jun 23, 1965

In Kornhauser v. … Commissioner v. Heininger, supra; Greene Motor Co., 5 T.C. 314 . * * * In Commissioner 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.

De Nobili Cigar Co. v. Commissioner

3 T.C.M. 83 · United States Tax Court · Feb 3, 1944

Walker Tobacco Co. v. … Since the Board as a whole acted to entertain the motion, the case is not governed by Commissioner v.

Barbara S. Fulton v. Commissioner

8 T.C.M. 455 · United States Tax Court · May 10, 1949

Fulton v. Commissioner. Estate of Weston M. Fulton, Deceased, Robert W. Fulton, Barbara S. Fulton, and John H. Murrian, Executors v. Commissioner. Barbara S. Fulton v. Commissioner Docket Nos. 16037, 16038. … Fulton Chairman of the Board 200 5 800 Barbara S. Fulton Total outstand- ing 10 1,000 The record does not show how Barbara acquired her common shares from her husband.

New Brunswick Trust Co. v. Commissioner

12 T.C. 1146 · United States Tax Court · Jun 28, 1949

New Brunswick Trust Company, Petitioner, v. Commissioner of Internal Revenue, Respondent New Brunswick Trust Co. v. Commissioner Docket No. 18052 United States Tax Court 12 T.C. 1146 ; 1949 U.S. Tax Ct. … See also The Poznan , 9 Fed. (2d) 838 ; Bell v. Heiner , 44 N. E. 576 .

Slaughter v. Commissioner

2 T.C.M. 528 · United States Tax Court · Jul 28, 1943

Slaughter v. Commissioner. Pearl Slaughter (Mrs. W. W. Slaughter) v. Commissioner. Slaughter v. Commissioner Docket Nos. 104633, 104637. United States Tax Court 1943 Tax Ct. Memo LEXIS 178 ; 2 T.C.M. (CCH) 528 ; T.C.M. … Slaughter became entitled to a salary of $10,000 from the Company, such sum being authorized by its board of directors and credited to W. W. Slaughter's account on its books.

Kozeneski v. Commissioner

9 T.C.M. 753 · United States Tax Court · Sep 12, 1950

Jennie Kozeneski v. Commissioner. Kozeneski v. Commissioner Docket No. 23039. United States Tax Court 1950 Tax Ct. Memo LEXIS 101 ; 9 T.C.M. (CCH) 753 ; T.C.M. (RIA) 50214 ; September 12, 1950 *101 Alec C. … The stepsister did not contribute to the support of the others in the household during 1945 but paid $6.00 a week toward her own board and lodging.