Case law

Peninsular Metal Products Corp. v. Commissioner

37 T.C. 172 · United States Tax Court · Nov 7, 1961

In American National Co. v. … Lucas v. American Code Co., 280 U.S. 445 ; Dixie Pine Products Co. v. Commissioner, 320 U.S. 516 .

Lehigh v. R. Co. v. Commissioner

12 T.C. 977 · United States Tax Court · Jun 9, 1949

Lucas v. American Code Co., 280 U. S. 445 ; Security Flour Mills Co. v. Commissioner, 321 U. S. 281 . A liability does not accrue so long as it remains contingent. Brown v. Helvering, 291 U. … Louis Railway v. Browning, 310 U. S. 362 , decided May 20, 1940, after the judgments here appealed from were entered. 42 Stat. L. 2200, Claims Agreement with Germany. See 45 Stat.

Merritt v. Commissioner

39 T.C. 257 · United States Tax Court · Oct 31, 1962

In Palmer v. … For instance, in Helvering v.

Johnson v. Commissioner

1 T.C. 1041 · United States Tax Court · May 4, 1943

Cromwell v. County of Sac, 94 U. S. 351 . … See Hammonds v.

Dave Fischbein Mfg. Co. v. Commissioner

59 T.C. 338 · United States Tax Court · Nov 27, 1972

board. … board.

Jerome Castree Interiors, Inc. v. Commissioner

64 T.C. 564 · United States Tax Court · Jul 14, 1975

of the corporation; thus, the board thereby established a condition on the payment of the bonuses. … Eckhard v. Commissioner, 182 F. 2d 547 (10th Cir. 1950), affg. on this issue 12 T.C. 384 (1949); R. E. Hughes, Jr., supra; C. E. Gullett, supra.

J. G. Dudley Co. v. Commissioner

36 T.C. 1122 · United States Tax Court · Feb 28, 1961

In Stanton Brewery, Inc. v. … And in New-market Manufacturing Co. v.

J. T. S. Brown's Son Co. v. Commissioner

10 T.C. 840 · United States Tax Court · May 17, 1948

C. 066 ; affd., 157 Fed. (2d) 321; Meurer Steel Barrel Co. v. Commissioner, 144 Fed. (2d) 282; * * * and Court Holding Co. v. Commissioner, 324 U. … In United States v.

Nicholls, North, Buse Co. v. Commissioner

56 T.C. 1225 · United States Tax Court · Aug 31, 1971

United Aniline Co. v. Commissioner, 316 F. 2d 701 (C.A. 1, 1963), affirming a Memorandum Opinion of this Court. He shared in the friendships and joined in the social activity on board on those occasions. … Memo. 1961-226 ; Commissioner v.

Byrne v. Commissioner

54 T.C. 1632 · United States Tax Court · Aug 24, 1970

Smith v. … Compare Webb v.

Catholic News Publishing Co. v. Commissioner

10 T.C. 73 · United States Tax Court · Jan 14, 1948

It is obvious that petitioner’s board of directors believed it a necessary one, and not without reasonable grounds for that belief. … Dunn & McCarthy v. Commissioner, 139 Fed. (2d) 242; Levitt & Sons v. Nunan, 142 Fed. (2d) 795. As the payment in question was proximately related to the conduct of the petitioner’s business, Kornhauser v.

Estate of Dieringer v. Comm'r

146 T.C. 117 · United States Tax Court · Mar 30, 2016

Decedent was chairman of the board of directors (board), vice president, and a shareholder of DPI. She actively participated in board and officer’s meetings. Eugene is president, a director, and a shareholder of DPI. … In a board resolution dated November 24, 2008, DPI’s board discussed a future purchase of decedent’s stock.

C. D. Johnson Lumber Corp. v. Commissioner

16 T.C. 1406 · United States Tax Court · Jun 20, 1951

As the Supreme Court said in Last Chance Mining Co. v. Tyler Mining Co., 157 U. … In Blackhawk-Perry Corporation v. Commissioner (C.

Valmont Industries, Inc. v. Commissioner

73 T.C. 1059 · United States Tax Court · Mar 12, 1980

Relying principally upon Satrum v. Commissioner, supra, and Brown-Forman Distillers Corp. v. … In both Satrum v. Commissioner, supra, and Brown-Forman Distillers Corp. v.

Adams Challenge (UK) Limited

United States Tax Court · Jan 21, 2021

The Fourth Circuit reaffirmed the “terminal date” principle in Georday En- terprises, Ltd. v. Commissioner, 126 F.2d 384 (4th Cir. 1942), aff’g a Memoran- dum Opinion of the Board of Tax Appeals. … Johnson v. Browne, 205 U.S. 309, 321 (1907). “If both can exist the repeal by implication will not be adjudged.” Ibid.

Gettler v. Commissioner

34 T.C.M. 442 · United States Tax Court · Mar 31, 1975

GETTLER, et al., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent * OF INTERNAL REVENUE, Respondent Gettler v. … V. Villa Romar.

Michigan Mobile Home & Recreational Vehicle Institute v. Commissioner

66 T.C. 770 · United States Tax Court · Jul 27, 1976

Corp. v. United States, 488 F.2d 684, 687-688 (2d Cir. 1973); Evanston-North Shore Board of Realtors v. United States, 320 F.2d 375 (Ct.Cl. 1963). … See also Cleveland Shopping News Co. v. Routzahn, 89 F.2d 902 (6th Cir. 1937).

Stevens v. Commissioner

46 T.C. 492 · United States Tax Court · Jun 30, 1966

In addition to training horses, which was done only at race tracks, petitioner provided a boarding service for horses at his farm. He charged approximately $100 per month for 'boarding on his farm. … Cohan v. Commissioner, 39 F. 2d 540 (C.A. 2, 1930).

Abernethy v. Commissioner

20 T.C. 593 · United States Tax Court · Jun 11, 1953

Cooke and others, the recommendation of the Board of Trustees was unanimously approved. … The petitioners cite the authority of Schall v. Commissioner, 174 F. 2d 893 , reversing 11 T. C. 111 .

Catawba Industrial Rubber Co. v. Commissioner

64 T.C. 1011 · United States Tax Court · Sep 9, 1975

See the cases cited above; also Tavannes Watch Co. v. Commissioner, 176 F. 2d 211 (2d Cir. 1949), revg. 10 T.C. 544 (1948); Hill York Corp. v. United States, an unreported case (S.D. … In Abingdon Potteries, Inc., supra, this Court did not recognize the creation of a trust by board action alone. In Dejay Stores v.