Case law

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.

Wilson v. Commissioner

1 T.C.M. 571 · United States Tax Court · Feb 6, 1943

Wilson v. Commissioner. Barbara Wilson v. Commissioner. Francis A. Wilson v. Commissioner. Barbara Wilson v. Commissioner. Wilson v. Commissioner Docket Nos. 103024, 103025, 105055, 105057. … In Schafer v.

Moss v. Commissioner

28 T.C.M. 1122 · United States Tax Court · Oct 14, 1969

In support of the proposition stated, the petitioners cite Helvering v. Taylor, 293 U.S. 507 ; Hoffman v. Commissioner, 298 F. 2d 784 ; Federal National Bank v. Commissioner, 180 F. 2d 494 ; *176 Welch v. … Commisioner, 297 F. 2d 309 ; and Tex-Penn Oil Co. v. Commissioner, 83 F. 2d 518 . 1147 It is our opinion that the contention is not soundly made and Marcello v.

Bohac Agency, Inc. v. Commissioner

30 T.C.M. 979 · United States Tax Court · Sep 8, 1971

of the Board Ben F. … Helvering v. Nat. Grocery Co., 304 U.S. 282 (1938) .

Madrigal v. Commissioner

76 T.C.M. 537 · United States Tax Court · Sep 29, 1998

Memo. 1998-345 UNITED STATES TAX COURT LUDIVINA MADRIGAL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12505-97. … Madrigal testified that he paid his aunt $200 every month in cash for room and board even though he reported a yearly income of only $1,800 on his 1994 Federal income tax return. Further, Mr.

Tavannes Watch Co. v. Commissioner

10 T.C. 544 · United States Tax Court · Mar 30, 1948

Tavannes Watch Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Tavannes Watch Co. v. Commissioner Docket No. 13163 United States Tax Court 10 T.C. 544 ; 1948 U.S. Tax Ct. … It held a meeting of its board of directors for the purpose of electing officers and for the purpose of filling a vacancy in the directorate, and depositing petitioner's contribution to it in its bank account, and using such

Getty v. Commissioner

91 T.C. 160 · United States Tax Court · Jul 27, 1988

Day v. Greene, 59 Cal. 2d 404 , 380 P.2d 385 (1963); Brown v. Superior Court, 34 Cal. 2d 559 , 212 P.2d 878 (1949). Moreover, as the Supreme Court recognized in Lyeth v. … United States v.

Hogan v. Commissioner

1 T.C.M. 208 · United States Tax Court · Dec 9, 1942

Hogan v. Commissioner. Novadean Hogan v. Commissioner. L. H. Choate v. Commissioner. Lucille Choate v. Commissioner. W. G. Choate v. Commissioner. Hogan v. … Cullen v. Commissioner, (C.C.A., 5th Cir.), 118 Fed. (2d) 651 McLean v. Commissioner, (C.C.A., 5th Cir.), 120 Fed. (2d) 942 . The authority of these cases has *65 not been weakened by Lee v.

Dana Distributors, Inc. v. Commissioner

56 T.C.M. 569 · United States Tax Court · Oct 31, 1988

Brown v. Helvering, 291 U.S. 192 (1934) ; Automobile Club of New York, Inc. v. Commissioner, 32 T.C. 906 , 913 (1959) , affd. 304 F.2d 781 (2d Cir. 1962) . … United States v. General Dynamics Corp., 481 U.S. (1987) . No deduction is permitted for a contingent liability. Brown v. Helvering, 291 U.S. 193 (1934) .

Franklin v. Commissioner

77 T.C. 173 · United States Tax Court · Aug 4, 1981

Watson v. Commissioner, 8 T.C. 569, 578-579 (1947); Ferris v. Commissioner, 38 B.T.A. 312, 316-317 (1938), affd. per curiam 102 F.2d 985 (2d Cir. 1939). See Rubnitz v. Commissioner, 67 T.C. at 629 ; Wilkerson v. … Stubbs, Overbeck & Associates v. United States, 445 F.2d 1142, 1146-1147 (5th Cir. 1971); Browne v. Commissioner, 73 T.C. 723, 731 (1980) (Hall, J., concurring); Benninghoff v.

Alumax Inc. and Consolidated Subsidiaries v. Commissioner

109 T.C. No. 8 · United States Tax Court · Sep 30, 1997

Under those facts, the Board of Tax Appeals held in J.A. Folger & Co. v. … Compare Billops v. Magness Constr. Co., 391 A.2d 196, 197-198 (Del. 1978), with Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 553 (2d Cir. 1994), and Carte Blanche (Singapore) PTE., Ltd., v. Diners Club Intl., Inc., 758 F.

SDI Netherlands B v. v. Commissioner

107 T.C. 161 · United States Tax Court · Oct 2, 1996

See Pallottini v. Commissioner, 90 T.C. 498, 500 (1988); cf. Law v. … See also Brown v. Commissioner, T.C. Memo. 1996-325 ; cf. Wicker v. Commissioner, T.C. Memo. 1993-431 , affd. without published opinion 50 F.3d 12 (8th Cir. 1995).

Shockley v. Comm'r

101 T.C.M. 1451 · United States Tax Court · May 2, 2011

See Sicker v. … The Board of Tax Appeals agreed and stated that the decision of the earlier case, that there was no valid notice, did not suspend the running of the period of limitations until 60 days after the decision of the Board at

Allen Industries, Inc. v. Commissioner

27 T.C.M. 542 · United States Tax Court · Jun 11, 1968

Welch v. Helvering, * * * 290 U.S. 111 (1933) . … Welch v. Helvering, supra.

Tobey v. Comm'r

60 T.C. 227 · United States Tax Court · May 17, 1973

He creates paintings, pictures, and drawings using oils, watercolors, ink, pencil, tempera, and chalk on paper, cardboard, canvas, composition board, wood, and other substances. … Robida v. Commissioner, supra at 1175 .

Giles v. Comm'r

89 T.C.M. 770 · United States Tax Court · Feb 17, 2005

See Golanty v. Commissioner, supra at 430; Burger v. Commissioner, T.C. Memo. 1985-523; accord McKeever v. Commissioner, T.C. … We understand the deduction of “boarding/training” to include the cost of boarding the horse at the training facility as part of its training. 18 In the same vein, we also reject petitioner’s assertion that she

Grunebaum v. Commissioner

50 T.C. 710 · United States Tax Court · Aug 6, 1968

Grunebaum, Petitioners v. Commissioner of Internal Revenue, Respondent; Kurt H. and Anneliese Grunebaum, Petitioners v. Commissioner of Internal Revenue, Respondent Grunebaum v. … Missouri Pacific Railroad Co. v. United States , 392 F. 2d 592 (Ct. Cl.).

Boggs v. Commissioner

50 T.C.M. 797 · United States Tax Court · Aug 15, 1985

Brown had purchased the Canadian residence for his son, with Mr. Brown making the $10,000 down payment thereon and leaving the younger Brown to make the mortgage payments when due. … Brown paid him a total of $4,000, a portion of which represented 10 or 11 overdue mortgage payments, with the remainder attributable to damage the younger Brown's pet dog had inflicted on certain personal property petitioner

Evans v. Commissioner

30 T.C. 798 · United States Tax Court · Jun 30, 1958

Subsequent to the Supreme Court decisions in the cases of Commissioner v. Estate of Church, 835 U. S. 682 (1949), and Estate of Spiegel v. Commissioner, 335 U. … In our opinion, petitioner’s decision to make the transfer here in question was caused by her desire to escape the impact of Commissioner v. Estate of Church, 335 U. S. 632 , and Estate of Spiegel v.

Northwestern Mut. Fire Asso. v. Commissioner

12 T.C. 498 · United States Tax Court · Mar 30, 1949

Paul Fire & Marine Insurance Co. v. … Vinup v. City of Seattle, 120 Pac. (2d) 464 ; 11 Wash. (2d) 630; Saviers v. Smith, 128 N. E. 269 ; 101 Ohio St. 132 . Cf. Keasbey & Mattison Co. v. Rothensies, 133 Fed. (2d) 894; Commissioner of Insurance v.