Case law

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.

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.

Guy F. Atkinson Co. v. Commissioner

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

Black, Ltd. v. … In Hahn v.

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.

Hanlon-Waters, Inc. v. United States

25 T.C. 1146 · United States Tax Court · Mar 6, 1956

Paragraph V provided that the petitioner would furnish to the Under Secretary of War a written statement showing the actual results of its operations for the fiscal year 1943 under the certification of independent public … representative, (a) to reopen the renegotiation in his discretion at any time within sixty (60) days after the contractor shall have filed with the Under Secretary of War a statement of financial statements provided for in Paragraph V

First Nat'l Co. v. Commissioner

32 T.C. 798 · United States Tax Court · Jun 30, 1959

Deputy v. du Pont, 308 U.S. 488 ; Commissioner v. Park, 113 F. 2d 352 , affirming 38 B.T.A. 1118 ; Autenreith v. Commissioner, 115 F. 2d 856 , affirming 41 B.T.A. 319 . … Gilman v. Commissioner, 53 F. 2d 47 , affirming 18 B.T.A. 1277 ; Commissioner v. Park, supra; Autenreith v. Commissioner, supra; United States v. Virgin, 230 F. 2d 880 .

Prendergast v. Commissioner

57 T.C. 475 · United States Tax Court · Jan 6, 1972

See also Cockrell v. United States, an unreported case (N.D. Tex. 1957, 1 A.F.T.R. 2d 394 , 58-1 U.S.T.C. par. 9159); Reardon v. United States, 158 F. Supp. 745 (S.D. 1958). … See also Hugh Browne, T.C. Memo. 1965-165 , affirmed without discussion of this issue 367 F. 2d 3S6 (C.A. 4, 1966). With regard to the occupancy of the taxpayer, compare Muse v.

Crowley v. Commissioner

34 T.C. 333 · United States Tax Court · May 31, 1960

Crowley and Paul V. Crowley and David V. … Crowley, Jr., David V. Crowley and Paul V.

Brighton Mills, Inc. v. Commissioner

7 T.C. 819 · United States Tax Court · Sep 20, 1946

The opinion of the Board of Tax Appeals in Cannon Valley Milling Co., supra, at page 769, referred to but did not discuss Sanford Cotton Mills, supra. The decision of the Circuit Court in Commissioner v. … North American Oil Consolidated v. Burnet, 286 U. S. 417 ; Moundridge Milling Co. v. Cream of Wheat Corporation, 105 Fed. (2d) 366.

Western Oaks Bldg. Corp. v. Commissioner

49 T.C. 365 · United States Tax Court · Jan 22, 1968

Brown and Donetta Brown (the Browns), are husband and wife whose legal residence was in Oklahoma City, Okla., at the *195 time the petition was filed in this case. … However, in Commissioner v.

Linen Thread Co. v. Commissioner

14 T.C. 725 · United States Tax Court · Apr 28, 1950

A., 7th Cir., 1930), 41 Fed. (2d) 141; Clark Brown Grain Co., 18 B. T. A. 937. See also United States ex rel. Greylock Mills v. Blair (App. D. C., 1923), 293 Fed. 846 ; Norwich Woolen Mills Corporation, 18 B. T. A. 303. … Greylock Mills v.

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.

Gray v. Commissioner

10 T.C. 590 · United States Tax Court · Apr 8, 1948

and Todd & Brown, Inc. … See Cohan v. Commissioner, 39 Fed. (2d) 540, 542.

Dr. Pepper Bottling Co. v. Commissioner

1 T.C. 80 · United States Tax Court · Nov 19, 1942

The regulation was obviously derived from statements in Commissioner v. Woods Machine Co. (C. C. A., 1st Cir.), 57 Fed. (2d) 635; certiorari denied, 287 U. S. 613 . … See Koshland v. Helvering, 298 U. S. 441 ; Helvering v. Gowran, 302 U. S. 238 .

Century Electric Co. v. Commissioner

15 T.C. 581 · United States Tax Court · Oct 31, 1950

But in the special meeting of petitioner’s board of directors on December 9,1948, at which the proposed transaction was approved, petitioner’s board of directors specifically adopted a resolution that “as a condition of said … Commissioner v. Wheeler, 324 U. S. 542 ; Helvering v. Reynolds Tobacco Co., 306 U. S. 110 ; United States v. Dakota-Montana Oil Co., 288 U. S. 459 ; Brewster v. Gage, 280 U. S. 327 .

Providence Wool Combing Co. v. Secretary of War

14 T.C. 979 · United States Tax Court · May 31, 1950

In Lichter v. … Lehman Machine Co. v. R. F. G. Price Adjustment Board, 10 T. C. 350, 355 ; Nathan Cohen v. Secretary of War, supra.

Anesthesia Service Medical Group, Inc. v. Commissioner

85 T.C. 1031 · United States Tax Court · Dec 24, 1985

Helvering v. LeGierse, 312 U.S. 531, 539-540 (1941); Commissioner v. Treganowan, 183 F.2d 288, 290 (2d Cir. 1950); Tighe v. Commissioner, 33 T.C. 557, 564 (1959). … (v) Other benefits.

McArdle v. Commissioner

11 T.C. 961 · United States Tax Court · Nov 30, 1948

The Board of Tax Appeals, after stating that the income tax law is concerned only with realized gains, said: * * * Moreover, Where the petitioner is, as here, on the cash basis, pretty clear evidence of his command over the … Stoner v. Commissioner, 79 Fed. (2d) 75; certiorari denied, 296 U. S. 650 . The Board followed the cases of Commissioner v. Cleveland Trinidad Paving Co., 62 Fed. (2d) 85, and Stoner v.

Hartman v. Commissioner

34 T.C. 1085 · United States Tax Court · Sep 22, 1960

As said by the Supreme Court in Helvering v. … See also our recent decision in Sims v. United States, 4 Cir., 252 F. 2d 434 . The Supreme Court has also held that even published rulings “have none of the force or effect of Treasury Decisions.” Helvering v. N.Y.