Case law

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

Seldin v. Commissioner

28 T.C.M. 1215 · United States Tax Court · Nov 3, 1969

Seldin v. Commissioner. Millard R. Seldin and Beverly Seldin v. Commissioner. Seldin v. Commissioner Docket Nos. 4213-66, 4218-66. United States Tax Court T.C. Memo 1969-233 ; 1969 Tax Ct. Memo LEXIS 63 ; 28 T.C.M. … Malat v. Riddell, 383 U.S. 569 (1966) .

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.

Estate of Cook v. Commissioner

66 T.C.M. 1523 · United States Tax Court · Dec 9, 1993

During 1979, decedent became a member of Newport's board of directors. He was a member of Newport's board through April 30, 1983. Decedent learned from Dr. … Diamond v. Commissioner , 930 F.2d at 375 ; Kantor v. Commissioner , 998 F.2d 1514 (9th Cir. 1993) ; Spellman v.

Parmer v. Commissioner

30 T.C.M. 1372 · United States Tax Court · Dec 21, 1971

See also United States v. Myra Foundation, 382 F. 2d 107 (C.A. 8, 1967), cited in Cullison v. United States, supra. … In Television Industries Inc. v.

Phillips v. Commissioner

24 T.C.M. 1457 · United States Tax Court · Oct 5, 1965

Phillips, et al. 1 v. Commissioner. Phillips v. Commissioner Docket Nos. 1361-63 - 1364-63. United States Tax Court T.C. Memo 1965-268 ; 1965 Tax Ct. Memo LEXIS 64 ; 24 T.C.M. (CCH) 1457 ; T.C.M. … We presume they rely heavily upon the Supreme Court case of United States v. Kaiser, 363 U.S. 299 (1960) . We agree with respondent.

Webb v. Commissioner

68 T.C.M. 1106 · United States Tax Court · Oct 31, 1994

See, e.g., Main-Hammond Land Trust v. Commissioner , 17 T.C. 942 , 956 (1951) , affd. 200 F.2d 308 (6th Cir. 1952) ; Browning v. Commissioner , T.C. Memo. 1974-80 . … In Browning v. Commissioner , supra , we held that an agreement between the IRS and the taxpayer as to the amount of deficiencies and additions to tax owed did not deprive this Court of jurisdiction.

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.

Hardinge Co. v. Commissioner

6 T.C.M. 650 · United States Tax Court · Jun 13, 1947

Hardinge Company, Inc. v. Commissioner. Hardinge Co. v. Commissioner Docket No. 3640. United States Tax Court 1947 Tax Ct. Memo LEXIS 185 ; 6 T.C.M. (CCH) 650 ; T.C.M. … REFUNDS AND CREDITS. * * * "(d) Overpayment Found by Board. - If the Board finds that there is no deficiency and further finds that the taxpayer has made an overpayment of tax in respect of the taxable year in respect of

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

Farmers Union Coop. Elevator Ass'n v. Commissioner

4 T.C.M. 490 · United States Tax Court · May 4, 1945

Farmers Union Co-operative Elevator Association v. Commissioner. Farmers Union Coop. Elevator Ass'n v. Commissioner Docket No. 133. United States Tax Court 1945 Tax Ct. Memo LEXIS 206 ; 4 T.C.M. (CCH) 490 ; T.C.M. … On January 22, 1941, the secretary of the board of directors made a report to the annual meeting of shareholders of the action taken by the board with respect to patronage dividends for 1940, and on January 21, 1942, he made

Tully Trust v. Commissioner

1 T.C. 611 · United States Tax Court · Feb 18, 1943

A. 633, the Board of Tax Appeals held that the conveyance in the prior year, while in written form was a transfer of ownership with a lease back, in substance was a loan secured by the property involved. … Commissioner, Commissioner v. Ashland Oil & Refining Co., Helvering v. Bashford, and Helvering v.

Craig v. Commissioner

7 T.C.M. 532 · United States Tax Court · Jul 29, 1948

Craig v. Commissioner. Craig v. Commissioner Docket No. 13843. United States Tax Court 1948 Tax Ct. Memo LEXIS 130 ; 7 T.C.M. (CCH) 532 ; T.C.M. (RIA) 48143 ; July 29, 1948 John J. Alder, Esq., for petitioner. George E. … Bercaw v. Commissioner (C.C.A., 4th Cir.), 165 Fed. (2d) 521 ; York v. Commissioner (D.C. App.), 160 Fed. (2d) 385 ; Barnhill v. Commissioner (C.C.A., 4th Cir.), 148 Fed. (2d) 913 ; William W.

West v. Comm'r

95 T.C.M. 1116 · United States Tax Court · Feb 13, 2008

See Abeles v.  - 8 - Commissioner, 91 T.C. 1019, 1025 (1988); Brown v. Commissioner, 78 T.C. 215, 219 (1982). … See Ng v. Commissioner, T.C. Memo. 2007-8.

Washington v. Commissioner

1 T.C.M. 682 · United States Tax Court · Mar 1, 1943

George Washington, Sr. v. Commissioner. Lina Washington v. Commissioner. Louise Washington v. Commissioner. Washington v. Commissioner Docket Nos. 106900, 106901, and 106902. United States Tax Court 1943 Tax Ct. … The trust instrument involved in this proceeding is the same instrument considered by the Board in the earlier proceeding.

Utah Power & Light Co. & Subsidiary v. Commissioner

62 T.C.M. 1089 · United States Tax Court · Oct 28, 1991

United States v. Hughes Properties, Inc. , 476 U.S. at 603 . … Globe Products Corp. v. Commissioner , 72 T.C. 609 , 621 (1979) ; Baltimore Transfer Co. v. Commissioner , 8 T.C. 1 , 7 (1947) .

Arlington Realty Co. v. Commissioner

21 T.C.M. 653 · United States Tax Court · May 24, 1962

Woods v. Stull, 182 Va. 888 , 30 S.E. 2d 675 , 682 . … See Dayton Co. v.

Jones v. Commissioner

24 T.C. 563 · United States Tax Court · Jun 30, 1955

Joseph Merrick Jones and Eugenie Penick Jones, Petitioners, v. Commissioner of Internal Revenue, Respondent Jones v. Commissioner Docket No. 53891 United States Tax Court 24 T.C. 563 ; 1955 U.S. Tax Ct. … The old floor boards were put down again with only a few replacements after the floors had been leveled. The same rafters and joists were used again, and only certain shingles were replaced in repairing the roof.

Estate of Manscill v. Commissioner

98 T.C. 413 · United States Tax Court · Apr 7, 1992

See, e.g., Estate of Wheeler v. … See also Estate of Bowling v.