Case law

Wesenberg v. Commissioner

69 T.C. 1005 · United States Tax Court · Mar 29, 1978

Commissioner v. Culbertson, 337 U.S. 733, 739-740 (1949). … See American Savings Bank v. Commissioner, supra; Roubik v. Commissioner, 53 T.C. 365 (1969).

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 .

North American Service Co. v. Commissioner

33 T.C. 677 · United States Tax Court · Jan 18, 1960

Corporation v. United States, —F. Supp. —(S.D. Tex., Mar. 17, 1959), on appeal (C.A. 5). … A similar view was expressed recently in United States v.

Guy F. Atkinson Co. v. Commissioner

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

Black, Ltd. v. … In Hahn v.

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.

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 .

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).

Estate of Maycann v. Commissioner

29 T.C. 81 · United States Tax Court · Oct 22, 1957

C. 707 ; Bogardus v. Commissioner, 302 U. S. 34 ; Brayton v. Welch, 39 F. Supp. 537 . … C. 916 ; Nixon v. United States, (E. D. Tenn., Aug. 18, 1957)—F. Supp.—. We think the case of Lengsfield v.

Lacy Contracting Co. v. Commissioner

56 T.C. 464 · United States Tax Court · Jun 1, 1971

Hyland, v. Commissioner, 175 F. 2d 422, 423 (C.A. 2, 1949), affirming a Memorandum Opinion of this Court. … Eckhard v. Commissioner, 182 F. 2d 547, 551 (C.A. 10, 1950), affirming on this issue 12 T.C. 384 (1949); Hyland v. Commissioner, supra, at 424; R. E.

Tennessee Valley Leather Co. v. Commissioner

8 T.C.M. 396 · United States Tax Court · Apr 28, 1949

Tennessee Valley Leather Company v. Commissioner. Tennessee Valley Leather Co. v. Commissioner Docket No. 16593. United States Tax Court 1949 Tax Ct. Memo LEXIS 205 ; 8 T.C.M. (CCH) 396 ; T.C.M. … Brown, M. M. Yates, and C. L. Teague.

Simon v. Comm'r

103 T.C. 247 · United States Tax Court · Aug 22, 1994

Respondent mainly relies on Clinger v. Commissioner, T.C. Memo. 1990-459 , and Browning v. Commissioner, T.C. … [Noyce v. Commissioner, 97 T.C. at 689 .] Browning v. Commissioner, T.C. Memo. 1988-293 , affd. 890 F.2d 1084 (9th Cir. 1989), is also distinguishable.

Hicks v. Commissioner

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

See James v. United States, supra; United States v. Mathews, 332 F. 2d 91 (C.A. 9, 1964); Henry C. Deneke, supra; and Leo M. … Any expense incurred in complying with the draft board’s order was clearly personal.

Goebel Brewing Co. v. Commissioner

43 T.C. 8 · United States Tax Court · Oct 7, 1964

In Commissioner v. H. B. … And in Lucas v.

Puget Sound Plywood, Inc. v. Commissioner

44 T.C. 305 · United States Tax Court · Jun 4, 1965

See, for example, Pomeroy Cooperative Co., 31 T.C. 674 , affirmed on this point 288 F. 2d 326 (C.A. 8); Smith & Wiggins Gin, Inc. v Commissioner, 341 F. 2d 341 (C.A. 5), affirming 37 T.C. 861 ; United States v. … United States v. Mississippi Chemical Co., 326 F. 2d 569, 573-574 (5th Cir. 1964); Pomeroy Cooperative Grain Co. v. Commissioner, 288 P. 2d 326, 328 (8th Cir. 1961). Plaintiff has met all these requirements.

Boyle Fuel Co. v. Commissioner

53 T.C. 162 · United States Tax Court · Nov 4, 1969

The burden of proving reasonableness is upon the petitioners, Botany Worsted Mills v. … Heil Beauty Supplies v. Commissioner, 199 F. 2d 193, 194 (C.A. 8, 1952), affirming a Memorandum Opinion of this Court.

Freytag v. Commissioner

89 T.C. 849 · United States Tax Court · Oct 21, 1987

See Forseth v. Commissioner, supra; Brown v. Commissioner, supra; Price v. Commissioner, 88 T.C. 860 (1987). In those three cases we found that the purported transactions were “factual shams” (Forseth v. … In Brown v.

Wolfers v. Commissioner

69 T.C. 975 · United States Tax Court · Mar 21, 1978

In Brown Shoe Co. v. … The Court distinguished Detroit Edison from Brown Shoe on the basis that Brown Shoe involved a contribution to capital, while Detroit Edison did not.

Burgess v. Commissioner

8 T.C. 47 · United States Tax Court · Jan 17, 1947

In numerous cases we have allowed approximate amounts for expenditures so paid under the reasoning of Cohan v. Commissioner, 39 Fed. (2d) 540. … Decision will be entered v/nder Rule 50.

Siebert v. Commissioner

53 T.C. 1 · United States Tax Court · Oct 2, 1969

-The board of directors of Excavating consisted of the same four individuals. A special meeting of the board of directors of Excavating was held on January 16, 1960. … In the recent case, Spillers v.

Frank v. Commissioner

54 T.C. 75 · United States Tax Court · Jan 26, 1970

He cites Eisner v. Macomber, 252 U.S. 189 (1920), and Miles v. … As the court said in Helvering v.