Case law

Toth v. Comm'r

128 T.C. 1 · United States Tax Court · Jan 18, 2007

See Sorrell v. Commissioner, 882 F.2d 484, 487-488 (11th Cir. 1989), revg. T.C. Memo. 1987-351 ; Lewis v. Commissioner, 861 F.2d 1232, 1233 (10th Cir. 1988), revg. T.C. Memo. 1986-155 ; Fishman v. … See Commissioner v. Idaho Power Co., 418 U.S. 1 (1974). In Hardy v. Commissioner, 93 T.C. 684, 693 (1989), affd. in part and remanded in part (10th Cir., Oct. 29, 1990), we overruled our Opinion in Hoopengarner v.

Consolidated Goldacres Co. v. Commissioner

8 T.C. 87 · United States Tax Court · Jan 21, 1947

Co. v. … See also Southern Pacific Co. v. Miller , 154 Pac. 929 . Studebaker Bros. Co. v.

Estate of Bahr v. Commissioner

68 T.C. 74 · United States Tax Court · Apr 25, 1977

v. … United States v. Childs, 266 U.S. 304, 309 (1924); Owens v. Commissioner, 125 F.2d 210, 213 (10th Cir. 1942); Jones v. United States, 371 F.2d 442, 450 (Ct. Cl. 1967); May v. Commissioner, 65 T.C. 1114 (1976); Time v.

Rosenthal v. Commissioner

48 T.C. 515 · United States Tax Court · Jun 30, 1967

In United States v. … The Supreme Court in Neuberger v.

Harbor Building Trust v. Commissioner

16 T.C. 1321 · United States Tax Court · Jun 12, 1951

Brown Co., 8 T. C. 112 (Acq., VII-1 C. B. 5). … Gregory v. Helvering, 293 U. S. 465 ; Helvering v. Bashford, 302 U. S. 454 .

Cherokee Textile Mills v. Commissioner

5 T.C. 175 · United States Tax Court · Jun 5, 1945

The Board member reserved decision on its admissibility. … Sumara v. United States (C. C. A., 2d Cir.), 129 Fed. (2d) 594; certiorari, denied, 317 U. S. 686 ; Blum Folding Paper Box Co., 4 T. C. 795 .

Merrill Lynch & Co. v. Comm'r

120 T.C. 12 · United States Tax Court · Jan 15, 2003

Benjamin v. Commissioner In Benjamin v. … Roebling v. Commissioner, supra at 55. 7. Monson v. Commissioner In Monson v.

Estate of Rockefeller v. Commissioner

83 T.C. 368 · United States Tax Court · Sep 24, 1984

The Board of Tax Appeals long ago allowed $l-a-year employees of the Government to deduct their actual ordinary and necessary expenses in carrying out their duties. Jackling v. … Commissioner, 9 B.T.A. 312 (1927); see also Pollock v. Commissioner, 10 B.T.A. 1297 (1928); Brown v. Commissioner, 13 B.T.A. 832 (1928). A similar conclusion was reached in Frank v.

Richey v. Commissioner

19 T.C. 926 · United States Tax Court · Mar 4, 1953

Simpson Richey, as Transferee of Assets of Wade and Richey, Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent. … Genevieve Mae Lee, as Transferee of Assets of Wade and Richey, Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent Richey v.

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.

Ginsberg v. Commissioner

46 T.C. 47 · United States Tax Court · Apr 19, 1966

Such action by the Commissioner was proper, sec. 7805(b), I.R.C. of 1954; 4 Automobile Club of Michigan v. Commissioner, 353 U.S. 180 ; Fruehauf Trailer Co. v. … Foundation, Inc. v. Commissioner, 324 F. 2d 633, 641-642 (C.A. 8), affirming 39 T.C. 93, 106-108 ; Wolinsky v. United States, 271 F. 2d 865, 868 (C.A. 2). But cf. Lesavoy Foundation v.

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.

Green v. Commissioner

28 T.C. 1154 · United States Tax Court · Sep 13, 1957

Petitioner has been employed as a schoolteacher by the Orleans Parish School Board continuously since 1930. For the first 11 years of her employment she received annual increments in salary. … The law, concerning the deductibility of such expenses, has been fairly well established since Hill v. Commissioner, 181 F. 2d 906 , which first laid out generally accepted rules to be followed in such cases.

Nicholson v. Commissioner

17 T.C. 1399 · United States Tax Court · Feb 28, 1952

Brown, Executrix, 26 B. T. A. 901, 906, affd. (C. A. 7), 69 F. 2d 602 , certiorari denied 293 U. S. 570 ; Elwood W. McGwire, 32 B. T. A. 1075, affd. (C. A. 7), 84 F. 2d 431 , certiorari denied 299 TJ. … Brown, Executrix, supra, 907.

Kresser v. Commissioner

54 T.C. 1621 · United States Tax Court · Aug 20, 1970

What was said by the Supreme Court in a somewhat different context is equally applicable here (Commissioner v. … Although there is general language in Smith v.

King v. Commissioner

77 T.C. 1113 · United States Tax Court · Nov 17, 1981

Fox v. United States, 397 F.2d 119, 122 (8th Cir. 1968); see also Helvering v. Stockholms &c. Bank, 293 U.S. 84, 87 (1934). … Judge Brown, in a concurring opinion, stated ( 551 F.2d at 89 ) that he agreed fully with the court’s opinion, but emphasized "that this decision is for this day and train only.”

P. H. & J. M. Brown Co. v. Commissioner

18 T.C.M. 708 · United States Tax Court · Aug 20, 1959

Brown Company v. Commissioner. P. H. & J. M. Brown Co. v. Commissioner Docket No. 55073. United States Tax Court T.C. Memo 1959-162 ; 1959 Tax Ct. Memo LEXIS 85 ; 18 T.C.M. (CCH) 708 ; T.C.M. … Brown leased unimproved land located *86 in Portland, Maine, from Eben Steele for 50 years.

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.

Brittingham v. Commissioner

57 T.C. 91 · United States Tax Court · Oct 14, 1971

See Harris v. United States, 413 F.2d 316 (C.A. 9, 1969); Colton v. United States, 306 F.2d 633 (C.A. 2, 1962); United States v. Tellier, 255 F.2d 441 (C.A. 2, 1958); Wilcoxon v. … Rindge in his letter refers to an inquiry he received from the Franchise Tax Board of California regarding Roberta’s income. Rindge in turn asks for Robert’s answers to the tax board’s questions.

Frontier Sav. Asso. v. Commissioner

87 T.C. 665 · United States Tax Court · Sep 24, 1986

In Rinker v. United States, 297 F. Supp. 370, 371 (S.D. … We cannot conclude, however, on the facts before us that the stock dividends were a mere subterfuge for cash distributions (see Rinker v.