Case law

Kenny v. Commissioner

4 T.C. 750 · United States Tax Court · Feb 8, 1945

Kenny, Petitioner, v. Commissioner of Internal Revenue, Respondent Kenny v. Commissioner Docket No. 3102 United States Tax Court 4 T.C. 750 ; 1945 U.S. Tax Ct. … C., by its resolution, a condition was imposed upon National, which National accepted, that National would adjust the compensation of certain of its officers, namely, the chairman of the board, the president and treasurer

Dalbo v. Commissioner

28 T.C.M. 1171 · United States Tax Court · Oct 16, 1969

Smith and Stanley Beattie, one of the School Board's attorneys, that no claim for defamation was ever considered during the negotiations. See Agar v. Commissioner, supra, at 284 . … Agar v. Commissioner, supra, at 284 .

Bessemer Limestone & Cement Co. v. Commissioner

22 T.C. 303 · United States Tax Court · May 14, 1954

Co. v. Boyd , 228 U.S. 482 , and Case v. … Wessel v. United States , 49 F. 2d 137 . See also Doyle v. Mitchell Bros.

Bissinger v. Commissioner

1 T.C.M. 998 · United States Tax Court · Apr 29, 1943

Buck (C.C.A., 2nd Cir.), 120 Fed. (2d) 775 ; reversing in part 41 B.T.A. 99 ; Commissioner v. Brown (C.C.A., 3rd Cir.), 131 Fed. (2d) 640 ; affirming 46 B.T.A. 782 ; certiorari denied, 63 S. … Buck, supra , and Commissioner v. Brown, supra , the trusts were long-term as distinguished from short-term trusts (see discussion of this factor in Verne Marshall, 1 T.C. 442 , and Ellis H.

Poirier & McLane Corp. v. Commissioner

63 T.C. 570 · United States Tax Court · Mar 10, 1975

Steel Cities Chemical Co. v. Virginia-Carolina Chemical Co., 2 Cir., 7 F.2d 280 ; Sinclair Cuba Oil Co., S. A., v. Manati Sugar Co., 2 F.Supp. 240 , D.C.S. D.N.Y.; Rogers Locomotive & Machine Works v. … Kelley, 88 N.Y. 234, 235 ; see Beaver Board Cos. v.

Organic Cannabis Foundation, LLC

United States Tax Court · Sep 27, 2023

In Kennedy v. … The regulations also seemingly would allow taxpayers to 21 The regulation reads as follows: “A request for a Board hearing filed after [the 180-day time limit] shall be dismissed by the Board, except that for good

Georgiou v. Commissioner

70 T.C.M. 1341 · United States Tax Court · Nov 16, 1995

There were two sets of Minutes of Special Meeting of the Board of Directors of JAI dated September 30, 1989. … In Baird v.

LabelGraphics, Inc. v. Commissioner

76 T.C.M. 518 · United States Tax Court · Sep 28, 1998

Commissioner, 399 F.2d at 606; Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. 1142, 1156 (1980). In Elliotts, Inc. v. … See, PMT, Inc. v. Commissioner, T.C.

Falcon Seaboard Drilling Co. v. Commissioner

30 T.C. 1081 · United States Tax Court · Aug 18, 1958

Stauss, Liquidating Trustees, Petitioner, v. Commissioner of Internal Revenue, Respondent Falcon Seaboard Drilling Co. v. Commissioner Docket No. 41552 United States Tax Court 30 T.C. 1081 ; 1958 U.S. Tax Ct. … His mother was chairman of the board of directors of that company, and he himself had been connected with it. Bernsen was in the oil supply business and had other oil interests.

Wells v. Commissioner

48 T.C.M. 1200 · United States Tax Court · Sep 24, 1984

RAYMOND WALTER WELLS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent Wells v. Commissioner Docket No. 24613-81. United States Tax Court T.C. Memo 1984-507 ; 1984 Tax Ct. Memo LEXIS 164 ; 48 T.C.M. … Once he was at the track, he would consult the "odds board" to determine whether an overall profit would be likely on a given race.

Matthews v. Commissioner

15 T.C.M. 204 · United States Tax Court · Feb 29, 1956

Elizabeth Robinson Matthews v. Commissioner. Matthews v. Commissioner Docket Nos. 55433, 57765. United States Tax Court T.C. Memo 1956-46 ; 1956 Tax Ct. Memo LEXIS 245 ; 15 T.C.M. (CCH) 204 ; T.C.M. … Hellstrom, supra ; Bogardus v. Commissioner, supra.

Brittingham v. Commissioner

66 T.C. 373 · United States Tax Court · Jun 3, 1976

Robert has never been a shareholder nor member of any governing board of Cerámica, and Dallas Ceramic owned no stock in Cerámica. … Helvering v. Horst, 311 U.S. 112 (1940).

Genuine Motor Parts of Pennsylvania, Inc. v. Commissioner

6 T.C.M. 927 · United States Tax Court · Aug 12, 1947

Genuine Motor Parts of Pennsylvania, Inc. v. Commissioner. Genuine Motor Parts of Pennsylvania, Inc. v. Commissioner Docket No. 10793. United States Tax Court 1947 Tax Ct. Memo LEXIS 112 ; 6 T.C.M. (CCH) 927 ; T.C.M. … After the Thirty Thousand ($30,000.00) Dollars in common capital stock shall have been issued to them or either of them, the compensation of LEVINSON and MINARD, or either of them, shall be such as the Board of Directors

Oliver v. Commissioner

2 T.C.M. 78 · United States Tax Court · May 12, 1943

Oliver v. Commissioner. Oliver v. Commissioner Docket No. 110237. United States Tax Court 1943 Tax Ct. Memo LEXIS 307 ; 2 T.C.M. (CCH) 78 ; T.C.M. (RIA) 43229 ; May 12, 1943 *307 Robert A. … As was so aptly expressed by the Board of Tax Appeals in the Richards case, what the petitioner "has done is to take certain assets individually owned and devoted them to a new purpose."

Weyenberg Shoe Mfg. Co. v. Commissioner

23 T.C.M. 1997 · United States Tax Court · Dec 17, 1964

In Peters v. … However, here we are hesitant to substitute our judgment for that of the board of directors. Welch v. Helvering, 290 U.S. 111 (1933) .

Foote v. Comm'r

110 T.C.M. 307 · United States Tax Court · Sep 22, 2015

The second audit, for petitioners’ tax years 1997 through 1999, was conducted by Revenue Agent Michael Brown (Agent Brown). … Corson v. Commissioner, 123 T.C. 202 (2004); Urbano v. Commissioner, 122 T.C. 384 (2004); Katz v. Commissioner, 115 T.C. 329 (2000); Hawksley v. Commissioner, T.C. Memo. 2000-354; Jacobs v. Commissioner, T.C.

Allison Corp. v. Commissioner

36 T.C.M. 689 · United States Tax Court · May 31, 1977

Co. v. … Cole v.

Easton v. Commissioner

1 T.C.M. 549 · United States Tax Court · Feb 5, 1943

Easton v. Commissioner. Joan F. Easton v. Commissioner. Suzanne E. Easton v. Commissioner. Vera H. Easton v. Commissioner. Easton v. Commissioner Docket Nos. 110974, 110975, 110976, 110977. … The Board held that the distributions constituted taxable dividends under the provisions of section 115 (g) of the Revenue Act of 1936, to the extent of the earnings available therefor.

Morrisdale Coal Mining Co. v. Commissioner

19 T.C. 208 · United States Tax Court · Nov 12, 1952

See Palmer v. Bender, 287 U. S. 551 (1938). … Such proposal, after having been approved on May 16, 1947, by a special board acting in lieu of the National Wage Stabilization Board, was approved by the President of the United States on May 17, 1947 ( 12 Fed.

Mojonnier & Sons, Inc. v. Commissioner

12 T.C. 837 · United States Tax Court · May 25, 1949

Florida Machine & Foundry Co. v. Fahs, supra ; Heberlein Patent Corporation v. United States , 105 Fed. (2d) 965 ; Bassick v. Commissioner , 85 Fed. (2d) 8 . Cf. Hazeltine Corporation v. … See Hawke v.