Case law

Zmuda v. Commissioner

79 T.C. 714 · United States Tax Court · Nov 8, 1982

The declaration of trust also provided that "resolutions of the board of trustees authorizing a special thing to be done shall be evidence that such act is within its power.” … See Epp v. Commissioner, supra.

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) .

City of Columbus v. Commissioner

106 T.C. 325 · United States Tax Court · May 14, 1996

Corp. v. Central States Pension Fund, 22 F.3d 725, 727 (7th Cir. 1994). … Woodward v. Commissioner, 397 U.S. 572 (1970) (articulating the “origin of the claim” test).

Bowden v. Commissioner

44 T.C.M. 1188 · United States Tax Court · Sep 22, 1982

Krist v. Commissioner, supra ; Marlin v. … See also Gibbons v. Commissioner, T.C. Memo. 1978-75 ; Haynie v. Commissioner, T.C. Memo. 1977-330 ↩ . 6. See Reidenbach v. Commissioner, T.C. Memo. 1981-642 . Compare, Haynie v. Commissioner, T.C. Memo. 1977-330 ↩ . 7.

Stewart v. Commissioner

55 T.C.M. 1730 · United States Tax Court · Aug 29, 1988

Patterson v. Buffalo Wood, Inc., 204 So.2d 853 , 854 (Miss. 1967) . … The boards of supervisors of the various counties are simply the state's agents for administering these properties. Washington County v. Riverside Drainage District, 131 So. 644 , 645 (Miss. 1931) .

Tomasso v. Commissioner

61 T.C.M. 2416 · United States Tax Court · Apr 16, 1991

Maddrix v. Commissioner , 83 T.C. 613 , 621 (1984) , *206 affd. 780 F.2d 946 (11th Cir. 1986) ; Wing v. Commissioner , 81 T.C. 17 (1983) ; Vastola v. Commissioner , 84 T.C. 969 (1985) ; Goldstone v. Commissioner , T.C. … Petitioner contends that a default could occur in any year of the sublease; thus, the test in Brown v. Commissioner , 799 F.2d 27 (2d Cir. 1986) , affg. a Memorandum Opinion of this Court, has been met.

Fearey v. Commissioner

2 T.C.M. 237 · United States Tax Court · Jun 8, 1943

Fearey v. Commissioner. Fearey v. Commissioner Docket No. 110614. United States Tax Court 1943 Tax Ct. Memo LEXIS 266 ; 2 T.C.M. (CCH) 237 ; T.C.M. (RIA) 43276 ; June 8, 1943 *266 Morton L. … In the Peabody case, the Board held that the petitioner there had sustained her burden and established that the preferred and common stock in that company did become worthless in 1932.

Anaheim Paper Mill Supplies, Inc. v. Commissioner

37 T.C.M. 403 · United States Tax Court · Mar 1, 1978

The founder, president, and chairman of the board of APMSI is Cosmo V. Taormina, father of petitioner Salvatore M. Taormina. … In addition, Taormina was selected by the Orange County disposal companies to represent them on the State Solid Waste Management Board.

Scott v. Commissioner

17 T.C.M. 619 · United States Tax Court · Jun 17, 1958

Harry Scott v. Commissioner. Scott v. Commissioner Docket No. 66518. United States Tax Court T.C. Memo 1958-113 ; 1958 Tax Ct. Memo LEXIS 114 ; 17 T.C.M. (CCH) 619 ; T.C.M. (RIA) 58113 ; June 17, 1958 Norman H. … The facts in the instant case closely parallel those in Commissioner v.

Rapelye v. Commissioner

5 T.C.M. 485 · United States Tax Court · Jun 13, 1946

Rapelye v. Commissioner. Rapelye v. Commissioner Docket No. 9326. United States Tax Court 1946 Tax Ct. Memo LEXIS 163 ; 5 T.C.M. (CCH) 485 ; T.C.M. … He rented a bachelor apartment in Washington, D.C., while he was in the employ of the War Production Board. On March 15, 1943, he left his full-time job with the War Production Board.

Rau v. Commissioner

25 T.C.M. 1313 · United States Tax Court · Nov 23, 1966

Rau v. Commissioner. Rau v. Commissioner Docket No. 2161-64. United States Tax Court T.C. Memo 1966-254 ; 1966 Tax Ct. Memo LEXIS 27 ; 25 T.C.M. (CCH) 1313 ; T.C.M. (RIA) 66254 ; November 23, 1966 *27 Raymond H. … grievances and complaints have been dealt with, to wit, that petitioner has not received his share of public benefits, and that he has been discriminated against by the New York Industrial Personnel Access Authorization Field Board

Tobjy v. Commissioner

25 T.C.M. 1354 · United States Tax Court · Dec 6, 1966

Ralph Tobjy v. Commissioner. Tobjy v. Commissioner Docket No. 3065-65. United States Tax Court T.C. Memo 1966-265 ; 1966 Tax Ct. Memo LEXIS 21 ; 25 T.C.M. (CCH) 1354 ; T.C.M. … Petitioner Ralph Tobjy, an electrical engineer employed by the Board of Education of New York City, is a resident of Brooklyn, New York. He was married during the year 1961.

Hatt v. Commissioner

28 T.C.M. 1194 · United States Tax Court · Oct 28, 1969

Hatt v. Commissioner. The Albert Johann & Sons Company, Inc. v. Commissioner. Hatt v. Commissioner Docket Nos. 5225-66, 5226-66. United States Tax Court T.C. Memo 1969-229 ; 1969 Tax Ct. Memo LEXIS 66 ; 28 T.C.M. … Haden Co. v.

Texasgulf, Inc. v. Commissioner

35 T.C.M. 158 · United States Tax Court · Feb 12, 1976

TEXASGULF INC. and SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Texasgulf, Inc. v. Commissioner Docket No. 7950-71. United States Tax Court T.C. Memo 1976-39 ; 1976 Tax Ct. … Washington Post Company v. United States, 405 F.2d 1279 (Ct. Cl. 1969) ; Lawyers' Title Guaranty Fund v. United States, 508 F.2d 1 (5th Cir. 1975) . 2.

Schwarzenbach v. Commissioner

4 T.C. 179 · United States Tax Court · Oct 9, 1944

Commissioner v. Prouty , 115 Fed. (2d) 331 ; Burnet v. Guggenheim , 288 U.S. 280 ; Sanford's Estate v. Commissioner , 308 U.S. 39 ; art. 3, Regulations 79, as amended by T. D. 5010 , C. B. 1940-2, p. 293. … As stated in Richardson v.

Chesapeake Corp. of Virginia v. Commissioner

17 T.C. 668 · United States Tax Court · Oct 10, 1951

Security Flour Mills Co. v. Commissioner , 321 U.S. 281 . … Lucas v.

Lots, Inc. v. Commissioner

49 T.C. 541 · United States Tax Court · Feb 28, 1968

At that time there was in effect a resolution of the City’s board of aldermen requiring the setting aside of a portion of each, subdivision as a park area. … However, in Anderson v.

Graham v. Commissioner

34 T.C.M. 329 · United States Tax Court · Mar 17, 1975

Houghton, 48 T.C. 656 (1967) ; Brown v. Lethert, 360 F.2d 560 (C.A. 8, 1966); Cohen v. United States, 297 F.2d 760 (C.A. 9, 1962); Luhring v. Glotzbach, 304 F.2d 556 (C.A. 4, 1962). … Phillips v. Commissioner, 283 U.S. 589 , 596 (1931) ; Brown v. Lethert, supra.

Bunton v. Commissioner

27 T.C.M. 9 · United States Tax Court · Jan 4, 1968

Bunton v. Commissioner. Bunton v. Commissioner Docket No. 1358-65. United States Tax Court T.C. Memo 1968-3 ; 1968 Tax Ct. Memo LEXIS 294 ; 27 T.C.M. (CCH) 9 ; T.C.M. … The facts in this case distinguish it from Wall v. United States, 164 F. 2d 462 (C.A. 4, 1947); Louis H.

National Biscuit Co. v. Commissioner

29 T.C. 409 · United States Tax Court · Dec 6, 1957

National Biscuit Company, Petitioner, v. Commissioner of Internal Revenue, Respondent National Biscuit Co. v. Commissioner Docket No. 54327 United States Tax Court 29 T.C. 409 ; 1957 U.S. Tax Ct. … Upon execution of such union contracts in October 1949, the petitioner, by notices dated November 22, 1949, which were posted on conspicuous bulletin boards in all its manufacturing plants, bakeries, sales branches, and other