Case law

Reitz v. Commissioner

61 T.C. 443 · United States Tax Court · Jan 9, 1974

Petitioners entered into no binding contract of sale which would allow us to attribute beneficial ownership of the stock to the board on the day the dividend was declared. See Moore v. Commissioner, supra; DeGuire v. … The record contains no evidence that the 'board participated in the decision to declare a dividend. See Miller v. Commissioner, supra.

Deupree v. Commissioner

1 T.C. 113 · United States Tax Court · Nov 24, 1942

board of directors on July 6, 1937. … income (the proceeds of the sale of property or compensation for services rendered or some other type of income) are paid to a third party designated by the taxpayer. * * * The Supreme Court, in the leading case of Corliss v.

Colwell v. Commissioner

64 T.C. 584 · United States Tax Court · Jul 17, 1975

Bogardus v. Commissioner, 302 U.S. 34, 40 (1937); Commissioner v. LoBue, 351 U.S. 243, 246 (1956); William A. Brown, supra. Petitioners rely almost exclusively on United States v. … E.g., Kaiser v. United States, supra; Woody v. United States, supra; William A. Brown, supra; John N.

Tinling v. Commissioner

7 T.C. 1393 · United States Tax Court · Dec 26, 1946

Hoitt, 119 Wash. 283 ; 205 Pac. 414 ; In re Brown's Estate, 124 Wash. 273 ; 214 Pac. 10 ; In re Hebert's Estate, 169 Wash. 402 ; 14 Pac. (2d) 6 ; State ex rel Van Moss v. … In re Dewey’s Estate, supra; Guye v. Guye, 63 Wash, 340; 115 Pac. 731 . In Julius Shafer, 2 B. T.

Victory Markets, Inc. v. Commissioner

99 T.C. 648 · United States Tax Court · Dec 23, 1992

The taxpayer, relying on Commissioner v. … Chelrob, Inc. v. Barrett, 57 N.E.2d 825 (N.Y. 1944); Lippel v. Hirsch, 119 N.Y.S.2d 453 (Sup. Ct. 1953).

Watnick v. Commissioner

90 T.C. 326 · United States Tax Court · Mar 9, 1988

Brown that Exxon would be willing to meet or better any other offers. … Brown’s partner, collaborated with Mr. Brown on the preparation of petitioner’s expert report. Prior to his partnership with Mr. Brown, Mr.

Ballantine v. Commissioner

46 T.C. 272 · United States Tax Court · May 19, 1966

Salvage v. Commissioner, 76 F. 2d 112 . … In support of this argument respondent cites Beals’ Estate v. Commissioner, supra; Salvage v. Commissioner, supra; Yost v. Commissioner, 155 F. 2d 121 ; and Emmette L. Barran, 39 T.C. 515 .

Middlebrook v. Commissioner

13 T.C. 385 · United States Tax Court · Sep 27, 1949

Brown in a partnership doing business as Metropolitan Buick Co. … Commissioner v. Tower, 327 U. S. 280 ; Commissioner v. Culbertson, 337 U. S. 733 .

Morgan v. Commissioner

33 T.C. 30 · United States Tax Court · Oct 13, 1959

Brown, Jr., Esq ., for the petitioners. Edward L. Newberger, Esq ., for the respondent. Black, Judge . … Gould v.

Orangeburg Mfg. Co. v. Commissioner

37 T.C. 251 · United States Tax Court · Nov 21, 1961

V, subpt. II, (F) (1) and (2) (pp. 120-1). … Petitioner refers, to the Supreme Court decision in 1938 in Electric Bond Co. v.

Zackim v. Commissioner

91 T.C. 1001 · United States Tax Court · Dec 6, 1988

United States v. LaFatch, 565 F.2d 81, 83-84 (6th Cir. 1977), cert. denied 435 U.S. 971 (1978); Moch v. … It therefore is to be invoked only after careful inquiry. * * * [Brown v. Felsen, 442 U.S. 127, 132 (1979).]

Collins v. Commissioner

61 T.C. 693 · United States Tax Court · Mar 7, 1974

The foundation's initial board of trustees consisted of petitioner and his two sisters, both of whom were registered nurses holding college degrees. By limiting board membership to his immediate family, Dr. … Geurkink v. United States , 354 F. 2d 629 , 631 (C.A. 7) ; Bouschor v. United States , 316 F. 2d 451 , 457-458 *161 (C.A. 8) ; De Masters v.

Franz v. Commissioner

58 T.C.M. 1357 · United States Tax Court · Feb 12, 1990

BROWN FRANZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Franz v. Commissioner Docket No. 20996-88 United States Tax Court T.C. Memo 1990-62 ; 1990 Tax Ct. Memo LEXIS 62 ; 58 T.C.M. (CCH) 1357 ; T.C.M. … In the Motion to Vacate, petitioner contends that her case is governed *64 by a previous order of this Court in the case of Texas Basic Education Systems v.

Nathan v. Commissioner

19 T.C. 865 · United States Tax Court · Feb 18, 1953

Brown, 16 T. C. 623 , cited by respondent, sustains his contention in the instant case, as does Thomas E. Hogg, 13 T. C. 361 . … In an Illinois case of Walters v. Walters, 94 N.

Wasserman v. Commissioner

24 T.C. 1141 · United States Tax Court · Sep 29, 1955

In Michaels v. Donato, 67 A. 2d 911 (N. … As said by the court in Michaels v.

L. M. Brown Abstract Co. v. Commissioner

1 T.C.M. 509 · United States Tax Court · Jan 30, 1943

Brown Abstract Company v. Commissioner. Union Title Company v. Commissioner. L. M. Brown Abstract Co. v. Commissioner Docket Nos. 105114, 105115. United States Tax Court 1943 Tax Ct. Memo LEXIS 475 ; 1 T.C.M. … The minutes of the regular meeting of the Union's board of directors held on December 14, 1937, read in part as follows: Mr.

Virginia Ice & Freezing Corp. v. Commissioner

30 T.C. 1251 · United States Tax Court · Sep 26, 1958

See Commissioner v. Court folding Co., 324 U. S. 331 (1945), where it was held that the sale was made by the corporation, and United States v. Cumberland Public Service Co., 338 U. … shall be adopted by a majority of the whole board at a meeting called for that purpose.

Byrne v. Commissioner

65 T.C. 473 · United States Tax Court · Dec 3, 1975

Brown, 380 U.S. 563, 570-571 (1965). In Hercules Gasoline Co. v. … It followed the holding of Helvering v.

Globe Corp. v. Commissioner

20 T.C. 299 · United States Tax Court · May 7, 1953

The Board held, following Continental Tie & Lumber Co. v. … The Board went on to say: "This was purely a matter of computation under the express direction of the statute."

Marlor v. Commissioner

27 T.C. 624 · United States Tax Court · Dec 26, 1956

Please note that this appointment is of a temporary nature, and that under Sec. 113 of the.By-laws of the Board of Higher Education, services beyond the period indicated in this notice are possible only if the Board takes … Welch v. Helvering, 290 U. S. 111 ; T. F. Driscoll, 4 B. T. A. 1008; Knut F. Larson, 15 T. C. 956 .