Case law

Brzezinski v. Commissioner

23 T.C. 192 · United States Tax Court · Oct 29, 1954

Botany Worsted Mills v. United States, 278 U. … , until the decision of the Board has become final.

Burroughs Corp. v. Commissioner

33 T.C. 389 · United States Tax Court · Nov 30, 1959

Burroughs Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent Burroughs Corp. v. Commissioner Docket No. 72023 United States Tax Court 33 T.C. 389 ; 1959 U.S. Tax Ct. … Guggenheim, supra [ 288 U.S. 280 ], or to modify the terms of the arrangement so as to make other disposition of the property, Sanford v.

Barnett v. Commissioner

69 T.C. 609 · United States Tax Court · Jan 26, 1978

However, at no time shall Barnett accept the position of Chairman of the Board of Directors. … Barrett v. Commissioner, supra at 289. Petitioners’ reliance on Barrett v. Commissioner, supra, is misplaced. In Barrett, the taxpayer was a retired corporate executive.

Hallmark Research Collective

United States Tax Court · Nov 29, 2022

Co. v. … Ward v.

Brittelle v. Commissioner

32 T.C. 1332 · United States Tax Court · Sep 30, 1959

State v. Sinar, 267 Wis. 91 , 65 N.W. 2d 43 . … State v. Mayor, etc., of City of Milwaukee, 189 Wis. 84 , 206 N.W. 210 . The school board is an administrative arm of the State for the conduct of public education. State v.

Garlock, Inc. v. Commissioner

58 T.C. 423 · United States Tax Court · Jun 5, 1972

In Eder v. … See, e.g., Helvering v. Nat. Grocery Co., 304 U.S. 282 (1938); Burnet v. Wells, 289 U.S. 670 (1933). See also Corliss v.

Davis v. Commissioner

22 T.C. 1091 · United States Tax Court · Aug 24, 1954

In Slee v. … Trinidad v. Sagrada Orden , 263 U.S. 578 , 44 S. Ct. 204 , 68 L. Ed. 458 . See also Huntington National Bank , 13 T. C. 760 , 769 ; Girard Trust Co. v. Commissioner , 122 F. 2d 108 ; Old Colony Trust Co. v.

First Chicago Corp. v. Commissioner

96 T.C. 421 · United States Tax Court · Mar 7, 1991

The board was also able to elect its own members, i.e., if there was a vacancy on the board. … vested in its board.

National Carbide Corp. v. Commissioner

8 T.C. 594 · United States Tax Court · Mar 25, 1947

The board of directors of the petitioners held an organization meeting each year and thereafter only met when called upon by Aireo to formalize action taken by the Aireo board. … Co. v. Lowe, supra.

Bryant v. Commissioner

2 T.C. 789 · United States Tax Court · Sep 29, 1943

Also see Last Chance Mining Co. v. Tyler Mining Co., 157 U. S. 683 , and New Orleans v. Citizens' Bank, 167 U. S. 371 , where the Supreme Court restated the same rule. … Decision will be entered v/nder Bule 60.

Chilhowee Mills, Inc. v. Commissioner

4 T.C. 558 · United States Tax Court · Jan 11, 1945

Petitioner cites United States v. Brown, 86 Fed. (2d) 798; Eichelberger & Co. v. Commissioner, 88 Fed. (2d) 874; and Ford Motor Co. v. United States, 9 Fed. Supp. 590, 604. … Art. 71, Regulations 74; Taylor Oil & Gas Co. v. Commissioner, 47 Fed. (2d) 108, affirming 15 B. T. A. 609; Burnet v. Lexington Ice & Goal Co., 62 Fed. (2d) 906; First National Bank of Greeley v.

Puget Sound Pulp & Timber Co. v. Commissioner

30 T.C. 398 · United States Tax Court · May 29, 1958

The pulp is brown in color, but more extensive cookifig makes it easier to bleach. Unbleached sulphate pulp is used for making paper in which strength is the prime consideration and the brown color is not objectionable. … Suitable pulpwoods for producing the former were more abundant and cheaper in this country, and for the commoner forms of brown paper and board, in which sulphate pulp is used, there are greater advantages in the integration

Blair v. Commissioner

63 T.C. 214 · United States Tax Court · Nov 18, 1974

Board of Junior College, District 504 v. Carey, 43 Ill. 2d 82 , 250 N.E. 2d 644 (1969); City of Chicago v. R.R. Bldg. Corp., 24 Ill. 2d 20 , 179 N.E. 2d 623 (1962). In Delano, Inc. v. … Co. v. Miller, 251 Ill. 58 , 95 N.E. 1027 (1911); Sanitary Dist. of Chicago v. Metropolitan W.S. E. Ry. Co., 241 Ill. 622 , 89 N.E. 800 (1909); Calumet River Ry. Co. v. Brown, 136 Ill. 322 , 26 N.E. 501 (1891).

Grant-Jacoby, Inc. v. Commissioner

73 T.C. 700 · United States Tax Court · Jan 16, 1980

Brown *205 , for the respondent. Simpson , Judge . … Armantrout v.

Diaz v. Commissioner

70 T.C. 1067 · United States Tax Court · Sep 27, 1978

Davis v. Commissioner, 65 T.C. 1014, 1019 (1976); Glenn v. Commissioner, 62 T.C. 270, 275 (1974). … Glenn v. Commissioner, supra; Weiszmann v. Commissioner, supra.

Dumont-Airplane & Marine Instruments, Inc. v. Commissioner

28 T.C. 1308 · United States Tax Court · Sep 30, 1957

In arguing that this action was proper, reliance is placed on Brown Shoe Co. v. Commissioner, 339 U. S. 583 (1950). … Dumont contends that it falls within the rationale of the Brown Shoe case.

Trustees Common Stock John Wanamaker Philadelphia Under Will of Wanamaker v. Commissioner

11 T.C. 365 · United States Tax Court · Sep 27, 1948

Following Mead Corporation v. … The amounts in question must accordingly be regarded as having been in effect paid to Mary Brown Warburton and Rodman Wanamaker II, and in turn paid over by them to petitioners. Berg an v. Commissioner (C. C.

Conti v. Commissioner

99 T.C. 370 · United States Tax Court · Sep 29, 1992

Brown, 557 F.2d 541, 556 (6th Cir. 1977); United States v. Addison, 498 F.2d 741, 743 (D.C. Cir. 1974); United States v. Stifel, 433 F.2d 431, 438, 441 (6th Cir. 1970). … United States v. Miller, 874 F.2d 1255, 1261 (9th Cir. 1989) (quoting Brown v. Darcy, 783 F.2d 1389 , 1397 n.14 (9th Cir. 1986)).

Human Engineering Institute v. Commissioner

61 T.C. 61 · United States Tax Court · Oct 18, 1973

See also Board of Regents v. Roth, 408 U.S. 564 , 570 fn. 7 (1972); Peres, v. Ledesma, 401 U.S. 82, 126-127 (1971). The petitioners’ right to a trial de novo in this Court satisfies the later hearing requirement. … Enochs v. Williams Packing Co., 370 U.S. 1, 6-7 (1962). See also Brown-Wheeler Co., 21 B.T.A. 755, 757 (1930).

Alabama Pipe Co. v. Commissioner

23 T.C. 95 · United States Tax Court · Oct 21, 1954

There shall be attached to such copy of the resolution of the board of directors a written declaration that the resolution of authorization was adopted by the board of directors during the taxable year, and such declaration … In Champlin v. Commissioner, 78 F. 2d 905 , affirming in part 28 B. T. A. 264, the court held that the taxpayer had exercised an option and could not rescind his action.