Case law

Masters v. Commissioner

25 T.C. 1093 · United States Tax Court · Feb 29, 1956

Paul Masters, Petitioner, v. Commissioner of Internal Revenue, Respondent. Bill Williams [Vasilios Vasiliades], Petitioner, v. Commissioner of Internal Revenue, Respondent Masters v. … Cohan v. Commissioner , 39 F. 2d 540 . Respondent's determination of the deficiencies herein is therefore approved.

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.

Broncatti v. Commissioner

42 T.C.M. 826 · United States Tax Court · Aug 24, 1981

See also Bolter v. Commissioner , T.C. Memo. 1981-378 ; Cooper v. Commissioner , T.C. Memo. 1981-369 ; Palmer v. Commissioner , T.C. Memo. 1981-354 ; Thelen v. Commissioner , T.C. Memo. 1981-302 ; Wenger v. … See Reinecke v. Smith , 289 U.S. 172 , 177-178 (1933) ; Corliss v. Bowers , 281 U.S. 376 , 377-378 (1930) ; Swallow v. United States , 325 F.2d 97 , 98 (10th Cir. 1963) , cert. denied 377 U.S. 951 (1964) ; Wright v.

Atwell v. Commissioner

17 T.C. 1374 · United States Tax Court · Feb 27, 1952

Webster Atwell et al., Petitioners, 1 v. Commissioner of Internal Revenue, Respondent Atwell v. … The minutes of the meeting of the board of directors of Texas held on July 14, 1947, show the interest of each of the purchasers in the note of Texas and recite that there was a principal balance due on the note at the time

Steinberg v. Comm'r

110 T.C.M. 466 · United States Tax Court · Nov 19, 2015

Thor Power Tool Co. v. … See, e.g., Nicolazzi v.

Caracci v. Comm'r

118 T.C. 379 · United States Tax Court · May 22, 2002

On July 11, 1995, the Sta-Home tax-exempt entities’ boards of directors authorized the conversion of those entities into S corporations. … See Kincaid v. United States, supra; Tilton v. Commissioner, supra; Estate of Hitchon v. Commissioner, supra; Estate of Trenchard v. Commissioner, supra; Estate of Higgins v. Commissioner, supra.

Pickle v. Commissioner

30 T.C.M. 1300 · United States Tax Court · Nov 30, 1971

Pickle v. Commissioner. Pickle v. Commissioner Docket Nos. 5930-69, 7676-70. United States Tax Court T.C. Memo 1971-304 ; 1971 Tax Ct. Memo LEXIS 26 ; 30 T.C.M. (CCH) 1300 ; T.C.M. … Petitioner challenges the arbitrariness of section 1.79-2(b)(3)(iii) of the regulations, citing Walsh v. United States, 322 F. Supp. 613 ↩ (E.D.N.Y. 1970) .

Casa Loma, Inc. v. Commissioner

39 T.C.M. 1251 · United States Tax Court · Mar 19, 1980

CASA LOMA, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Casa Loma, Inc. v. Commissioner Docket No. 11317-76. United States Tax Court T.C. Memo 1980-78 ; 1980 Tax Ct. Memo LEXIS 505 ; 39 T.C.M. … See Beauchamp & Brown Groves Co., 44 T.C. 117 , 123-124 (1965) , affd. 371 F.2d 942 (C.A. 9, 1967); cf. sec. 337(c)(2)(B) and United States Holding Co., 44 T.C. 323 (1965) .

Bryant v. Commissioner

58 T.C.M. 235 · United States Tax Court · Sep 27, 1989

Petitioner owned 56 percent of the stock in American Magnetics; Alan Brown (Brown) and Charles Repenn (Repenn) held the remaining 44 percent. … Based upon Brown's enthusiastic report, his review of the data brought back by Brown, and his discussions with his C.P.A. and with his attorney, petitioner decided to invest in the Austin *534 Mine, as did Brown and Repenn

Mitchell & Co. v. Commissioner

20 T.C. 110 · United States Tax Court · Apr 20, 1953

Mitchell & Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Mitchell & Co. v. Commissioner Docket No. 26415 United States Tax Court 20 T.C. 110 ; 1953 U.S. Tax Ct. … Labor strongly opposed arbitration until 1920, when a local board of arbitration was set up.

Estate of Lewis v. Commissioner

55 T.C.M. 22 · United States Tax Court · Feb 3, 1988

LEWIS, III and FRANK APPLEBY, Co-Executors, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent; ESTATE OF ROSEMARY R. LEWIS, Deceased, FRANK APPLEBY, Successor Personal Representative, Petitioner v. … Petitioners contend, however, that we did not consider the application of section 7502 in Brown. We do not believe that section 7502 directs a different result.

Estate of Atkinson v. Commissioner

31 T.C. 1241 · United States Tax Court · Mar 27, 1959

Linton Atkinson and Rosalea Atkinson, Petitioners, v. Commissioner of Internal Revenue, Respondent. Warren M. Atkinson, Petitioner, v. Commissioner of Internal Revenue, Respondent Estate of Atkinson v. … Boomhower v. United States , 74 F. Supp. 997 (1947) .

Luke Gibson & Breeana Gibson

United States Tax Court · Jan 6, 2026

Brown, for respondent. … See Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).

Dunham v. Comm'r

86 T.C.M. 344 · United States Tax Court · Sep 8, 2003

Brown, docket No. 8368-02L; Harold V. and Imogene N. Pahl, docket No. 11572-02L; Charles and Teresa Brodman, docket No. 16598-02L. … Crain v. Commissioner, 737 F.2d 1417, 1418 (5th Cir. 1984); see Brodman v. Commissioner, supra; Kish v. Commissioner, T.C. Memo. 1998-16; Fisher v. Commissioner, T.C. Memo. 1996-277.

Harris Hardwood Co. v. Commissioner

8 T.C. 874 · United States Tax Court · Apr 24, 1947

Harris Hardwood Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent Harris Hardwood Co. v. Commissioner Docket No. 4424 United States Tax Court 8 T.C. 874 ; 1947 U.S. Tax Ct. … By the terms thereof the board of directors of the insurance company was required *236 annually to ascertain and apportion the divisible surplus accruing upon the policy at the end of each policy year.

Meyer v. Commissioner

42 T.C.M. 1738 · United States Tax Court · Nov 24, 1981

MEYER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Meyer v. Commissioner Docket No. 1189-78. United States Tax Court T.C. Memo 1981-676 ; 1981 Tax Ct. Memo LEXIS 67 ; 42 T.C.M. (CCH) 1738 ; T.C.M. … Stoltzfus v. United States , 398 F.2d 1002 , 1004 (3d Cir. 1968) ; Ross Glove Co. v. Commissioner , 60 T.C. 569 , 608 (1973) . We hold that respondent has failed to carry his burden.

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

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

La Belle v. Commissioner

47 T.C.M. 1078 · United States Tax Court · Feb 13, 1984

E.g., Furnish v. Commissioner, 262 F.2d 727 (9th Cir. 1958) ; Brown v. Commissioner, 51 T.C. 116 (1968) . However, any claim that her signature was executed under duress is meritless. … Brown v.