Case law

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.

Pfingst v. Commissioner

6 T.C.M. 316 · United States Tax Court · Mar 26, 1947

Osborne Pfingst v. Commissioner. Pfingst v. Commissioner Docket No. 8441. United States Tax Court 1947 Tax Ct. Memo LEXIS 266 ; 6 T.C.M. (CCH) 316 ; T.C.M. (RIA) 47072 ; March 26, 1947 Theodore B. … The sale of the machinery to Owen Osborne, Inc., was confirmed by the board of directors at a meeting held on July 22, 1940.

Stiles v. Commissioner

69 T.C. 558 · United States Tax Court · Jan 10, 1978

of any litigation resting on the same allegation or allegations; or it may, if it deems proper, on its own motion, act as arbiter of the controversy arising from such allegation, or through an officer, as one member of a board … See Williams v. United States, supra at 527; Pozzi v. Commissioner, supra at 128; Holden v. Commissioner, 6 B.T.A. 605 (1927). In Williams v.

Glazer v. Commissioner

40 T.C.M. 1065 · United States Tax Court · Aug 26, 1980

AND ANNE GLAZER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Glazer v. Commissioner Docket No. 8107-79. United States Tax Court T.C. Memo 1980-337 ; 1980 Tax Ct. Memo LEXIS 250 ; 40 T.C.M. … (RIA) 80337 ; August 26, 1980 , Filed Barbara Anne Brown , for the petitioners. Louis T. Conti , for the respondent.

Graham v. Commissioner

82 T.C. 299 · United States Tax Court · Feb 27, 1984

Graham was president, chairman of the board, and principal shareholder of Meridian. … See Riland v. Commissioner, 79 T.C. at 207 ; Jackson v. Commissioner, 73 T.C. at 401 ; Greenberg’s Express, Inc. v. Commissioner, 62 T.C. at 328 ; Human Engineering Institute v. Commissioner, 61 T.C. at 66 ; Suarez v.

Johnson v. Commissioner

3 T.C.M. 930 · United States Tax Court · Sep 11, 1944

Coley, 45 B.T.A. 405 ; Hammans v. Commissioner, 121 Fed. (2d) 4 ; Amelia H. Cohen Trust et al. v. Commissioner, 121 Fed. (2d) 689 . … See Alpers v. Commissioner, supra.

Watts v. Comm'r

113 T.C.M. 1507 · United States Tax Court · Jun 14, 2017

Most attractive to the Watts brothers, however, was Wellspring’s express desire to keep the brothers on board to manage Golf’s day-to-day operations. … The remaining 2.5% of the common interests were split between a member of the extended Watts family and a Wellspring-appointed member of the board of directors.

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.

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).

Vernon M. Leslie, Jr. v. Commissioner

2014 T.C. Summary Opinion 65 · United States Tax Court · Jul 10, 2014

-5- v. Helvering, 292 U.S. 435, 440 (1934); Segel v. … See Commissioner v. Brown, 380 U.S. 563, 570-571 (1965); Crane v. Commissioner, 331 U.S. 1, 6-7 (1947); Texaco Inc. & Subs. v.

J. Aron & Co. v. Commissioner

22 T.C.M. 788 · United States Tax Court · Jun 12, 1963

Aron & Company, Inc. v. Commissioner. J. Aron & Co. v. Commissioner Docket No. 89398. United States Tax Court T.C. Memo 1963-164 ; 1963 Tax Ct. Memo LEXIS 180 ; 22 T.C.M. (CCH) 788 ; T.C.M. … In Peters v.

Wells-Lee v. Commissioner

23 T.C.M. 1931 · United States Tax Court · Dec 9, 1964

Leslie E. and Avis V. … See Deputy v. duPont, 308 U.S. 488 (1940) ; Welch v. Helvering, 290 U.S. 111 (1933) ; Noland v. Commissioner, 269 F. 2d 108 (C.A. 4, 1959; and Caldwell & Co., 26 B.T.A. 790 (1932) , affd. 65 F. 2d 1012 (C.A. 2, 1933).

General Pencil Co. v. Commissioner

3 T.C.M. 603 · United States Tax Court · Jun 17, 1944

General Pencil Company v. Commissioner. General Pencil Co. v. Commissioner Docket No. 3616. United States Tax Court 1944 Tax Ct. Memo LEXIS 200 ; 3 T.C.M. (CCH) 603 ; T.C.M. (RIA) 44214 ; June 17, 1944 *200 G. H. … In 1941 petitioner's board of directors decided on steps to improve the management of the company and thereafter advised the *201 company's president, Raymond A.

Williams v. Commissioner

37 T.C.M. 1270 · United States Tax Court · Aug 8, 1978

The board of directors of Machine consisted of Clint, Jeanne, George Chandler (an employee) and Taylor. … Roschuni v.

Dallas v. Comm'r

92 T.C.M. 313 · United States Tax Court · Sep 28, 2006

Financial Status and Senior Management Petitioner chairs DGA’s board. … to the board that did not tax-affect S corporation income.

Federal Bulk Carriers, Inc. v. Commissioner

66 T.C. 283 · United States Tax Court · May 18, 1976

Therefore, respondent asserts, relying on Arrowsmith v. … Compare Bank of Palm Beach & Trust Co. v. Commissioner, 476 F.2d 1343 (Ct. Cl.), with Estate of Carter v. Commissioner, 453 F.2d 61 (2d Cir.).)

Estate of McGlue v. Commissioner

1 T.C.M. 981 · United States Tax Court · Apr 26, 1943

Edith McGlue, Executrix v. Commissioner. Estate of McGlue v. Commissioner Docket No. 98446. United States Tax Court 1943 Tax Ct. Memo LEXIS 342 ; 1 T.C.M. (CCH) 981 ; T.C.M. (RIA) 43202 ; April 26, 1943 *342 Ralph P. … States Circuit Court of Appeals for the Fourth Circuit, Helvering v.

JONES v. COMMISSIONER

2005 T.C. Summary Opinion 9 · United States Tax Court · Jan 26, 2005

Commissioner, supra; Brown v. Commissioner, supra. … See sec. 6015(e); Brown v. Commissioner, supra.

Hoover Co. v. Commissioner

72 T.C. 206 · United States Tax Court · Apr 24, 1979

The Board of Tax Appeals had previously held that these futures constituted hedges. The Fifth Circuit, however, did not agree. … The Board of Tax Appeals, with six dissents, held that this expenditure constituted an ordinary and necessary business expense.

Bluefries-New York, Inc. v. Commissioner

5 T.C.M. 58 · United States Tax Court · Jan 31, 1946

Bluefries-New York, Inc. v. Commissioner. Bluefries-New York, Inc. v. Commissioner Docket No. 5367. United States Tax Court 1946 Tax Ct. Memo LEXIS 275 ; 5 T.C.M. (CCH) 58 ; T.C.M. … Lucas v. Ox Fibre Brush Co., 281 U.S. 115 .