Case law

Entwicklungs und Finanzierungs A.G. v. Commissioner

68 T.C. 749 · United States Tax Court · Aug 29, 1977

Demkowitz v. Commissioner, 551 F.2d 929 (3d Cir. 1977). 7 We turn now to application of the origin test to those claims. Without regard to the particular legal theories advanced by Cleanamation, Brown v. … Stoody v. Commissioner, 66 T.C. 710 , 715 n. 2 (1976); Seay v. Commissioner, 58 T.C. 32 (1972).

Frank Spingolo Warehouse Co. v. Commissioner

37 T.C. 1 · United States Tax Court · Oct 6, 1961

Frank Spingolo Warehouse Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Frank Spingolo Warehouse Co. v. Commissioner Docket No. 76980 United States Tax Court 37 T.C. 1 ; 1961 U.S. Tax Ct. … Snyder Sons Co. v.

Greenberg v. Comm'r

112 T.C.M. 4746 · United States Tax Court · Nov 9, 2016

Ladd Christman Brown, Jr., for respondent. … V.

Warren Auto. Club, Inc. v. Commissioner

8 T.C.M. 577 · United States Tax Court · Jun 14, 1949

Warren Automobile Club, Inc. v. Commissioner. Warren Auto. Club, Inc. v. Commissioner Docket No. 12702. United States Tax Court 1949 Tax Ct. Memo LEXIS 156 ; 8 T.C.M. (CCH) 577 ; T.C.M. … The members annually elect a board of trustees which constitutes petitioner's governing body. In such election each member is entitled *158 to one vote.

Steffens v. Commissioner

49 T.C.M. 54 · United States Tax Court · Nov 9, 1984

In Steffens v. … Members of the board of directors of Kansas-Nebraska were elected to serve on the board by stockholder vote on an annual basis.

Keating v. Comm'r

94 T.C.M. 383 · United States Tax Court · Oct 11, 2007

Petitioner purchased and boarded her first horse when she was 15 years old. In 1996, when petitioner began her horse activity, petitioner realized a lifelong dream of working with horses. … In 2001, petitioner began boarding horses for, and leasing horses to, other individuals and providing horse clinics.

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.

McKean v. Commissioner

42 T.C.M. 1709 · United States Tax Court · Nov 19, 1981

Shortly after August 22, 1975, petitioners noticed that the entire top or crown of the black oak tree had turned brown. None of the leaves on other trees in the area had turned brown. … Estate of Floyd Falese v. Commissioner , 58 T.C. 895 , 899 (1972) ; McSpadden v. Commissioner , 50 T.C. 478 (1968) ; Sanderling, Inc. v. Commissioner , 66 T.C. 743 , 758 (1976) .

Giles v. Comm'r

91 T.C.M. 684 · United States Tax Court · Jan 31, 2006

The zoning ordinance permits breeding and raising of horses but prohibits Falling Water Way from being used as a livery stable or a boarding stable. … The new zoning laws allow up to 24 horses to be kept on the property but prohibit the operation of a livery stable or boarding stable.

Pessin v. Commissioner

44 T.C. 590 · United States Tax Court · Jul 16, 1965

Pessin and Frances Pessin, Petitioners, v. Commissioner of Internal Revenue, Respondent Pessin v. Commissioner Docket No. 4901-63 United States Tax Court 44 T.C. 590 ; 1965 U.S. Tax Ct. … Brown, Jr ., for the petitioners. Richard M. Schwartz , for the respondent. Pierce, Judge . PIERCE *590 Respondent determined a deficiency of $ 7,377.16 in the income tax of the petitioners, Arnold G.

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 .

Throop v. Commissioner

67 T.C.M. 1946 · United States Tax Court · Jan 10, 1994

GEORGENE THROOP, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Throop v. Commissioner Docket No. 20643-92 United States Tax Court T.C. Memo 1994-10 ; 1994 Tax Ct. Memo LEXIS 8 ; 67 T.C.M. … Brown, Jr.

Universal Mfg. Co. v. Commissioner

68 T.C.M. 305 · United States Tax Court · Aug 2, 1994

Brown, Leigh D. Roadman , and Daniel T. Hartnett . For respondent: Judy Jacobs Miller. … Coleman was the sole member of WNC's board *383 of directors from the time of WNC's incorporation until his resignation from the board effective on November 10, 1985. Mr.

Grams v. Commissioner

41 T.C.M. 448 · United States Tax Court · Nov 26, 1980

GRAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Grams v. Commissioner Docket No. 2378-79. United States Tax Court T.C. Memo 1980-528 ; 1980 Tax Ct. Memo LEXIS 57 ; 41 T.C.M. (CCH) 448 ; T.C.M. … During the calendar year 1976, the Scholarship Plan paid $1,749.19 to the University of Northern Colorado for tuition, fees, room and board, and bookstore charges incurred by Michele A. Grams.

Kreis v. Commissioner

29 T.C.M. 770 · United States Tax Court · Jun 24, 1970

See Bingler v. Johnson, 394 U.S. 741 (1969) . … . *196 On the authority of Bingler v.

Harold S. Smith v. Commissioner

6 T.C.M. 1323 · United States Tax Court · Dec 24, 1947

Smith v. Commissioner. Harold S. Smith v. Commissioner Docket No. 12210. United States Tax Court 1947 Tax Ct. Memo LEXIS 6 ; 6 T.C.M. (CCH) 1323 ; T.C.M. … Brown, 7 T.C. 715 , is adverse to his position here, but he asks for a reconsideration of that decision.

Botwinick v. Commissioner

50 T.C.M. 1161 · United States Tax Court · Sep 24, 1985

Michael, Jane, and a friend, Carmela Wagner, were the sole members of the charter organization's board of directors. … Kalgaard v. Commissioner, 764 F.2d 1322 , 1323 (9th Cir. 1985) , *135 affg. a Memorandum Opinion of this Court; 3 Hall v.

416 Main St. Corp. v. Commissioner

2 T.C.M. 579 · United States Tax Court · Aug 6, 1943

Hinchman, Jr. as its board of directors. Since December 17, 1937 the petitioner has at all times operated as a corporation through its directors and officers. … On and after March 22, 1938 dividends were paid to the stockholders of the petitioner from time to time to the present time upon action of the board of directors.

Consolidated Foods Corp. v. Commissioner

66 T.C. 436 · United States Tax Court · Jun 14, 1976

Co. v. … See Connery v. United States, 460 F.2d 1130, 1133 (3d Cir. 1972); Spitalny v. United States, 430 F.2d 195, 198 (9th Cir. 1970); Anders v. United States, 462 F.2d 1147, 1149 (Ct.

Abramo v. Commissioner

78 T.C. 154 · United States Tax Court · Jan 29, 1982

Brown , for the petitioner in docket No. 4708-79. Sandra M. Gilmore , for the respondent. Ekman , Judge . * Parker, J ., dissenting. Simpson , J ., agrees with this dissenting opinion. … In Commissioner v.