Case law

McGowan v. Commissioner

67 T.C. 599 · United States Tax Court · Dec 29, 1976

Southern Coal & Coke Co., 301 U.S. 495 (1937); Rhode Island Unemployment Compensation Board v. Conway, 77 R.I. 48, 50 , 73 A. 2d 109 (1950). … See Helvering v. Davis, 301 U.S. 619 (1937); Cain v. United States, 211 F.2d 375 (5th Cir. 1954). In Helvering v.

Weiland v. Commissioner

44 T.C.M. 1396 · United States Tax Court · Oct 14, 1982

Beaver v. Commissioner, 55 T.C. 85 , 91 (1970) ; Fisher v. Commissioner, 54 T.C. 905 (1970) ; Haber v. Commissioner, 52 T.C. 255 (1969) , affd. 422 F. 2d 198 (5th Cir. 1970) . Cf. Chism's Estate v. … Berthold v. Commissioner, 404 F. 2d 119 , 122 (6th Cir. 1968) , affg. a Memorandum Opinion of this Court; Chism's Estate v. Commissioner, supra at 959-960 ; Fisher v. Commissioner, supra at 909-910 ; Haber v.

Porter v. Commissioner

28 T.C.M. 1489 · United States Tax Court · Dec 29, 1969

Porter v. Commissioner. Porter v. Commissioner Docket No. 1720-68. United States Tax Court T.C. Memo 1969-288 ; 1969 Tax Ct. Memo LEXIS 2 ; 28 T.C.M. (CCH) 1489 ; T.C.M. … He became a member of the guild by submitting art work to its board of directors, and later became a member of the board.

Kern v. Commissioner

55 T.C.M. 667 · United States Tax Court · Apr 25, 1988

In Stephenson v. … Deputy v. duPont, 308 U.S. 488 (1940) .

Cho v. Commissioner

35 T.C.M. 1442 · United States Tax Court · Oct 12, 1976

A final attempt by Pacwood's Board at assessing its shareholders failed. With no options remaining, Pacwood's Board of Directors voted on January 4, 1966 to liquidate the assets of the company. … Horne v. Commissioner, 523 F. 2d 1363 (9th Cir. 1975) , affg. 59 T.C. 319 (1972) ; United States v. Hoffman, 423 F. 2d 1217 (9th Cir. 1970) (relying on Stratmore v.

Avis Indus. Corp. v. Commissioner

70 T.C.M. 641 · United States Tax Court · Sep 11, 1995

Estate of Hall v. Commissioner , 92 T.C. 312 , 338 (1989) ; Chiu v. … Owensby & Kritikos, Inc. v.

Gregory J. Podlucky & Karla S. Podlucky

United States Tax Court · May 5, 2022

Huet reiterated that the board never approved the proposal and that the document in question appeared to be one of many “board document[s] that [Greg] altered.” … Magnon v.

Penn v. Commissioner

11 T.C.M. 776 · United States Tax Court · Jul 28, 1952

Albert Penn v. Commissioner. Ralph Penn v. Commissioner. Penn v. Commissioner Docket Nos. 24254 and 27550. United States Tax Court 1952 Tax Ct. Memo LEXIS 131 ; 11 T.C.M. (CCH) 776 ; T.C.M. … Lockard v. Commissioner, 166 Fed. (2d) 409 , followed. Charles J. Munz, Jr., Esq., and Sidney R. Reed, Esq., both of 608 S. Hill St., Los Angeles 14, Calif., for the petitioners. H. A.

HARRY FOX, INC. v. COMMISSIONER

37 T.C.M. 1847-53 · United States Tax Court · Nov 14, 1978

HARRY FOX, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent HARRY FOX and DOLORES FOX, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent HARRY FOX, INC. v. … See Pahl v. Commissioner, 67 T.C. 286 , 292-293 (1976) ; Oswald v. Commissioner, 49 T.C. 645 ↩ (1968) . 4.

Linder v. Commissioner

18 T.C.M. 341 · United States Tax Court · Apr 9, 1959

John Linder, Petitioner v. Commissioner. Robert Dickman, Viola Dickman, Husband and Wife v. Commissioner. Linder v. Commissioner Docket Nos. 66878, 67040. United States Tax Court T.C. Memo 1959-69 ; 1959 Tax Ct. … Brown, Esq., 20 West Main Street, Norwalk, Ohio, for petitioner John Linder. Frank J. Hiltz, Esq., Citizens Bank Building, Norwalk, Ohio, for petitioners Robert Dickman and Viola Dickman. Frank W.

Becker v. Commissioner

46 T.C. 613 · United States Tax Court · Aug 12, 1966

Shares shall be made available in the discretion of the Board of Directors from authorized unissued or reacquired common stock, which latter stock is hereinafter referred to as Treasury Stock. … . ‡ ‡ v Section 5.

Setty Gundanna and Prabhavathi Katta Viralam v. Commissioner

136 T.C. 151 · United States Tax Court · Feb 14, 2011

VIRALAM v. … See Addis v.

Cooperative Grain & Supply Co. v. Commissioner

32 T.C.M. 795 · United States Tax Court · Jul 24, 1973

COOPERATIVE GRAIN AND SUPPLY CO., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Cooperative Grain & Supply Co. v. Commissioner Docket No. 6132-64. United States Tax Court T.C. Memo 1973-164 ; 1973 Tax Ct. … Brown Leonard Brown Joe Schmit Joe Schmitbauer Lester Heuertz S. L. Heuertz L. A.

Lockwood Realty Corp. v. Commissioner

17 T.C.M. 247 · United States Tax Court · Mar 31, 1958

In presenting its argument petitioner has primarily relied upon Wilshire & Western Sandwiches, Inc., v. Commissioner, 175 Fed. (2d) 718 ; Rowan v. United States, 219 Fed. (2d) 51 ; Earle v. W. J. … Express Publishing Co. v. Commissioner, 143 Fed. (2d) 386 ; *201 Canal Navigation & Trading Co. v. Commissioner, 168 Fed. (2d) 512 .

Armstrong v. Commissioner

66 T.C.M. 1502 · United States Tax Court · Dec 8, 1993

Hines v. Commissioner , 72 T.C. 715 , 720 (1979) ; West v. Commissioner , T.C. Memo. 1992-617 , 64 T.C.M. 1108 , 1111 ; Estate of Olsen v. Commissioner , T.C. … . *609 Thus, in Hines v.

Spector v. Commissioner

67 T.C.M. 2601 · United States Tax Court · Apr 7, 1994

Brown v. Commissioner, supra . A legal obligation may be imposed on a spouse by a divorce *160 decree or incurred by the spouse in an agreement incident to the divorce. Sec. 71(a)(1); Taylor v. … That distinction was noted in Brown v.

Estate of Levy v. Commissioner

46 T.C.M. 910 · United States Tax Court · Aug 2, 1983

Finally, in Brown v. … In fact, in Lundie and Brown, the courts of New Jersey specifically enforced such powers.

Savage v. Commissioner

42 T.C.M. 21 · United States Tax Court · Jun 2, 1981

Petitioners are in the process of building a new house in a different location on the Brown City property. … The cited regulation, sustained by this Court in Sanford v.

Wise v. Commissioner

75 T.C.M. 1514 · United States Tax Court · Jan 5, 1998

Creighton was the chief executive officer and chairman of the board of WC. … Commissioner v. Schleier, supra at 336-337.

Anna Elise Walton

United States Tax Court · Mar 30, 2021

She provided consulting work mostly to nonprofit clients, including Brown University and the National Geographic Society, as well as to her former employer, CLG. Ms. … See id.; see also Stough v.