Case law

Zarkin v. United States

29 T.C. 642 · United States Tax Court · Jan 13, 1958

Hoffman v. United States, supra; Hug Co. v. War Contracts Price Adjustment Board, supra. … Co. v. War Contracts Price Adjustment Board, supra; Pechtel v. United States, supra; Warner v. War Contracts Price Adjustment Board, 14 T. C. 1320 (1950).

O'Malley v. Commissioner

91 T.C. 352 · United States Tax Court · Aug 25, 1988

The pension fund’s litigation defense costs policy was originally adopted by resolution at a meeting of the board of trustees of the pension fund (board) on February 15, 1978. … In DePinto v. United States, supra, the court denied the taxpayer’s deduction of legal fees and losses arising out of his position as a member of the board of directors of a corporation.

Green Bay & W. R. Co. v. Commissioner

3 T.C. 372 · United States Tax Court · Feb 28, 1944

The Seventh Circuit recently in Commissioner v. … We think the facts of the instant case are no stronger for the taxpayer than were the facts in Commissioner v. Schmoll Fils Associated, Inc., 110 Fed. (2d) 611.

Rafferty v. Commissioner

55 T.C. 490 · United States Tax Court · Dec 14, 1970

At all times pertinent hereto and to the present, petitioners have jointly owned all of the outstanding shares of stock of Rafferty Brown Steel Co., Inc. … We deem respondent’s arguments based on Gregory v.

C. F. Mueller Co. v. Commissioner

55 T.C. 275 · United States Tax Court · Nov 9, 1970

Any officer may be removed either with or without cause at any time by vote of the board of trustees. ARTICLE V Powers and Duties of Officers Section 1. … In United States v.

Dixon v. Commissioner

28 T.C. 338 · United States Tax Court · May 8, 1957

Lucas v. Pilliod Lumber Co., 281 U. S. 245 , affirming 7 B. T. A. 591, arose under the Revenue Act of 1918. … Spies v. United States, 317 U. S. 492 . The respondent’s determination against the petitioners of the addition to tax for fraud is sustained.

Kinsey v. Commissioner

58 T.C. 259 · United States Tax Court · May 10, 1972

Pointing to Jacobs v. United States, 280 F. Supp. 437 (S.D. Ohio 1966), affd. 390 F. 2d 877 (C.A. 6, 1968), and W. B. … In a general discussion of cases similar to the one at hand, the District Court in Winton v. Kelm, 122 F. Supp. 649 (D.

H. Fendrich, Inc. v. Commissioner

25 T.C. 262 · United States Tax Court · Nov 18, 1955

Keneipp v. United States, (C. A., D. C., 1950) 184 F. 2d 263 . … United States v. Andrews, 302 U. S. 517 (1938), and United States v. Garbutt Oil Co., 302 U. S. 528 (1938).

Norton v. Commissioner

40 T.C. 500 · United States Tax Court · Jun 7, 1963

People v. Ashley, 267 P. 2d 271 (Cal. App. Super. 1954). … People v. Gould, 270 P. 2d 551 (Cal. App. 1954), and People v. Schmidt, supra at 221 .

West Virginia Steel Corp. v. Commissioner

34 T.C. 851 · United States Tax Court · Aug 15, 1960

He performed the usual duties of a company president and was a member of the board of directors. The other directors comprising the three-man board were F. A. Prince and E. F. Jones. … United States v. Anderson, 269 U.S. 422 (1926). We hold that petitioner could not accrue as an expense of 1953 the $25,000 in question. Abingdon Potteries, Inc., 19 T.C. 23 (1952).

Peter J. Schweitzer, Inc. v. Commissioner

30 T.C. 42 · United States Tax Court · Apr 16, 1958

Smith was controlled by the Brown & Williamson Tobacco Corporation. Ecusta was organized during the year 1938. … However, the shive in the seed flax tow appeared in the finished paper as brown specks.

Penn v. Comm'r

51 T.C. 144 · United States Tax Court · Oct 24, 1968

See Helvering v. Clifford, 309 U.S. 331, 335-336 . The cases of Skemp v. Commissioner, 168 F. 2d 598 (C.A. 7) reversing 8 T.C. 415 , and Brown v. … Skemp v. Commissioner, 168 F. 2d at 599-560 , Brown v. Commissioner, 180 F. 2d at 929 , followed in Albert T. Felix, 21 T.C. 794 .

Estate of Sowell v. Commissioner

74 T.C. 1001 · United States Tax Court · Aug 7, 1980

In Estate of Jones v. … Alch, 58 N.M. 796 , 277 P.2d 299 ; Brown v. Brown, 53 N.M. 379 , 208 P.2d 1081 .” Gregg v. Gardner, 338 P.2d 68, 74 (1963).

San Francisco Stevedoring Co. v. Commissioner

8 T.C. 222 · United States Tax Court · Jan 30, 1947

United States v. Anderson, 269 U. S. 422 ; Continental Tie & Lumber Co. v. United States, 286 U. S. 290 ; Spring City Foundry Co. v. Commissioner, 292 U. S. 182 ; United States v. … S. 88 ; Putnam's Estate v. Commissioner, 324 U. S. 393 ; H. Liebes & Co. v. Commissioner, 90 Fed. (2d) 932; Mertens Law of Federal Income Taxation, sec. 12.60.

Citizens & Southern Corp. v. Commissioner

91 T.C. 463 · United States Tax Court · Sep 6, 1988

Bennett Brown, chief executive officer of petitioner, testified that petitioner had bid for such deposits, although unsuccessfully. Petitioner contends that Midlantic National Bank/Merchants v. Commissioner, T.C. … Wagner & Brown v. E.W. Moran Drilling Co., 702 S.W.2d 760, 773 (Tex. Civ. App. 1986). Rule 201 of the Texas Rules of Evidence is derived verbatim from rule 201 of the Federal Rules of Evidence. Wagner & Brown v. E.W.

Clearview Apartment Co. v. Commissioner

25 T.C. 246 · United States Tax Court · Nov 4, 1955

Clearview Apartment Company, Petitioner, v. Commissioner of Internal Revenue, Respondent Clearview Apartment Co. v. Commissioner Docket No. 52030 United States Tax Court 25 T.C. 246 ; 1955 U.S. Tax Ct. … Brown, Jr., Esq ., for the petitioner. Edward Pesin, Esq ., for the respondent. Raum , Judge .

Universal Casting Corp. v. Commissioner

37 T.C. 107 · United States Tax Court · Oct 31, 1961

See, e.g., Wilbur Security Co. v. Commissioner, 279 F. 2d 657 , affirming 31 T.C. 938 , and O.H. Kruse Grain & Milling v. Commissioner, 279 F. 2d 123 , affirming a Memorandum Opinion of this Court. … Petitioner argues that John Kelley Co. v.

Marks v. Commissioner

8 T.C. 1255 · United States Tax Court · Jun 26, 1947

Petitioner relies on the one case of Commissioner v. Hyman, 135 Fed. (2d) 49, which affirmed the opinion of the Board of Tax Appeals, 46 B. T. A. 992. The question there was the same as in the instant case. … Miller v. Handy, 33 La. Ann. 160, 164 ; Risher v. Risher, 179 La. 1 ; Guss v. Mathews, 179 La. 1033 .

Guy F. Atkinson Co. v. Commissioner

82 T.C. 275 · United States Tax Court · Feb 16, 1984

Black, Ltd. v. … In Hahn v.

Benz v. Commissioner

63 T.C. 375 · United States Tax Court · Dec 17, 1974

Petitioner boarded all the dogs except Katrinka during 1968. … All of them except Katrinka were boarded by Ferchen through the end of May 1969. After June 1, 1969, Spot and Beau were boarded and trained by Thomas Getler (hereafter Getler).