Case law

Ditunno v. Commissioner

80 T.C. 362 · United States Tax Court · Feb 7, 1983

In particular, petitioner asserts that his gambling losses were trade or business deductions, qualifying as deductions from gross income under section 62(1). … As a result, he argues that petitioner’s gambling loss deductions did not qualify under section 62 as deductions from gross income allowable in computing adjusted gross income.

Estate of Gordon v. Commissioner

70 T.C. 404 · United States Tax Court · Jun 6, 1978

If Dave’s estate carries its burden of showing, in the words of the regulation, that the order of deaths “cannot be established by proof,” it has also established, in the words of Dave’s will, that “it is doubtful” which … App. 440 , 125 N.E.2d 812, 814 (1955) (“clearly speculatory”); In re Meyer’s Estate, 276 App.

Advo, Inc. & Subsidiaries v. Commissioner

141 T.C. No. 9 · United States Tax Court · Oct 24, 2013

By adopting these regulations, Treasury clearly intended a different interpretation of these terms. (continued... … The Supreme Court has established a two-prong test for determining whether to afford an agency pronouncement Chevron deference.

Wilson v. Commissioner

51 T.C. 723 · United States Tax Court · Feb 5, 1969

They were clearly the evidences of the water companies’ debts to repay advances used to finance the expansion of facilities. … The Court held that those provisions in the note sufficiently established its registered form. Gerard v.

Maryland Deposit Ins. Fund Corp. v. Commissioner

88 T.C. 1050 · United States Tax Court · Apr 27, 1987

MSSIC was an insurance fund established by the State of Maryland in 1962 for the purpose of insuring savings account deposits with savings and loan associations doing business in Maryland that did not qualify for FSLIC insurance … Clearly, estimates are permissible in calculating IBNR insurance losses.

Zeta Beta Tau Fraternity, Inc. v. Commissioner

87 T.C. 421 · United States Tax Court · Aug 13, 1986

Zeta Beta, therefore, contends that section 1.501(c)(10)-l, Income Tax Regs., in its exclusion of national college fraternities from tax exemption under section 501(c)(10), establishes an arbitrary distinction that discriminates … Clearly, like the Masons, Zeta Beta operates under the lodge system and its local chapters engage in some activities that concedely further the charitable and educational goals of the fraternity.

Hicks v. Commissioner

47 T.C. 71 · United States Tax Court · Oct 19, 1966

However, it is not sufficient to establish that Paragould was his “tax home” in 1961 for a section 162(a) (2) deduction. … Any expense incurred in complying with the draft board’s order was clearly personal.

Thompson v. Commissioner

78 T.C. 558 · United States Tax Court · Apr 8, 1982

He further contends that the circumstances of petitioners are clearly covered by section 6013(b)(2)(C) and Dritz v. … To qualify as a return, the Form 1040 must "state specifically the amounts of gross income and the deductions and credits claimed.” Conforte v.

Schuster v. Commissioner

50 T.C. 98 · United States Tax Court · Apr 17, 1968

The entire business of the proprietorship, including its accounts receivable, was transferred to a corporation on October 31, 1961, in a nonrecognizable transaction which qualified under section 351, I.R..C. 1954, and we … A deduction for an addition to a bad debt reserve under these circumstances was clearly unreasonable, and the $7,432.04 addition to the reserve claimed by petitioners was properly disallowed as a deduction by the Commissioner

Georgia-Pacific Corp. v. Commissioner

63 T.C. 790 · United States Tax Court · Mar 31, 1975

The new method is no doubt preferable to most taxpayers, because it defers income longer, but we cannot find that petitioner has established that the earlier method fails clearly to reflect income. … Petitioner argues in the alternative that because the reorganization qualified as tax free under sections 361 and 368(a)(1)(C), there can be no gain under regulations section 1.1502-19.

Mountain State Ford Truck Sales, Inc. v. Commissioner

112 T.C. 58 · United States Tax Court · Mar 2, 1999

In requiring that goods for which a taxpayer adopted the LIFO method be inventoried at cost, Congress presumptively was aware of the established regulatory definition of the term “cost” in inventory tax accounting. … be sustained because respondent changed that method to an impermissible method which does not clearly reflect income.

Connecticut Mut. Life Ins. Co. v. Commissioner

106 T.C. 445 · United States Tax Court · Jun 26, 1996

In order to qualify for deduction under section 162(a), five requirements must be satisfied. … Our review of the plan documents in question indicated that the reversion of any assets from the VEBA was clearly prohibited. Finally, in Moser v.

Gestrich v. Commissioner

74 T.C. 525 · United States Tax Court · Jun 4, 1980

We held that “something more than an unfulfilled duty or obligation on the part of the taxpayer” is required to qualify him for allowance of the dependency exemption. … He clearly spent a significant portion of his time working on his book and other materials.

Bullock v. Commissioner

26 T.C. 276 · United States Tax Court · May 18, 1956

The Velo-King debenture bonds do not qualify as “securities” within the meaning of section 112 (b) (3). … Neither party offered any opinion evidence by qualified experts in the appraisal of this type of security.

Pettus v. Commissioner

54 T.C. 112 · United States Tax Court · Jan 27, 1970

Petitioners established identical trusts for the benefit of each of their minor children. … Pettus established a trust for the benefit of his daughter, Rachael Anne Pettus, on February 28, 1964, the date of her birth.

Bell v. Commissioner

85 T.C. 436 · United States Tax Court · Sep 5, 1985

The Charitable Contributions Issue The Universal Life Church, Inc., of Modesto, California (hereinafter ulc, INC.), issued a charter to petitioners in 1979 to establish a local congregation of that church. … Although not revealed by their income tax returns for the respective years, which were introduced in evidence, petitioners contend that their claimed contributions were made to ulc, INC., a qualified charitable donee, and

L. E. Shunk Latex Products, Inc. v. Commissioner

18 T.C. 940 · United States Tax Court · Aug 29, 1952

The record is barren of any showing, however, that petitioners had grounds on which to file such an application or that they were in any way qualified for such relief. … Respondent has done nothing to establish the basis on which such an application might have been filed or the conditions required for its successful prosecution.

Lesher v. Commissioner

73 T.C. 340 · United States Tax Court · Nov 26, 1979

That fact is important in establishing that petitioners were selling neither their inventory nor property held “primarily for sale to customers in the ordinary course of his trade or business.” … storage of feed or equipment) which does not qualify it for the investment credit under this or other definitions of qualifying property.

Lamport Co. v. Commissioner

17 T.C. 1079 · United States Tax Court · Dec 29, 1951

Department 15 was established by the petitioner in 1932. Goods were purchased for that department by the pound and sold to customers by the yard. … However, this record would not justify the granting of any relief even if the petitioner clearly qualified for relief as it claims, under two of the subparagraphs of section 722 (b), i. e., even if the base period depression

Anschutz Co. v. Commissioner

135 T.C. 78 · United States Tax Court · Jul 22, 2010

TAC is a wholly owned qualified subch. … The PVFCs and the SLAs were clearly related. One could not occur without the other.