Case law

Pacific Vegetable Oil Corp. v. Commissioner

26 T.C. 1 · United States Tax Court · Apr 5, 1956

C. 216, 220 ; Kahuku Plantation Co. v. Commissioner, 132 F. 2d 671 , affirming 43 B. T. A. 784; Brown v. Helvering, 291 U. S. 193 ; Crescent Cotton Co., 5 B. T. A. 850; and David J. Joseph Co. v. … Brown v. Helvering, supra. The reason underlying the rule is that a liability does not accrue while it remains contingent.

Cooper v. Commissioner

67 T.C. 870 · United States Tax Court · Feb 28, 1977

Petitioner is governed in his employment by the orders of his immediate superiors at the fire station — the Fire Chief and the Board of Fire Commissioners (the board). … See Welch v. Helvering, 290 U.S. 111 (1933).

Asheville Mica Co. v. Commissioner

34 T.C. 664 · United States Tax Court · Jun 30, 1960

Vance Brown and S. Herbert Brown. … Herbert Brown and the four children of W. Vance Brown.

Thompson v. Commissioner

12 T.C.M. 348 · United States Tax Court · Mar 31, 1953

Helena Thompson v. Commissioner. Thompson v. Commissioner Docket No. 32410. United States Tax Court 1953 Tax Ct. Memo LEXIS 315 ; 12 T.C.M. (CCH) 348 ; T.C.M. (RIA) 53104 ; March 31, 1953 *315 1. … Since January, 1943 she has been employed by the Dade County School Board as an elementary school teacher. Her earnings were $1,963 in 1947, $2,392.68 in 1948 and $2,973.36 in 1949.

Zehman v. Commissioner

27 T.C. 876 · United States Tax Court · Feb 28, 1957

The single question presented involves a deduction for wage payments in excess of an amount determined as allowable by the Wage Stabilization Board. … United States v. Excel Packing Co., (C. A. 10) 210 F. 2d 596 .

Gokey Properties, Inc. v. Commissioner

34 T.C. 829 · United States Tax Court · Aug 12, 1960

held at the end of such year (with the exception of the year 1938 when the board of directors meeting was held after the end of that year). … Co. v. Commissioner, 284 U.S. 552, 560 (1932). It has been said that “[stockholders have no absolute right to dividends until they are declared. A creditor has a right to his interest in any event.” Commissioner v.

Edward Orton, Jr., Ceramic Foundation v. Commissioner

56 T.C. 147 · United States Tax Court · Apr 26, 1971

Cl. 1961); Parker v. Commissioner, 365 F. 2d 792 (C.A. 8, 1966), affirming in part a Memorandum Opinion of this Court; and Fides Publishers Ass'n. v. United States, 263 F. Supp. 924 (N.D. Ind. 1967). … Sico Foundation v. United States, 295 F. 2d 924, 925, 926 (Ct. Cl. 1961).

Morton v. Commissioner

12 T.C. 380 · United States Tax Court · Mar 22, 1949

v. … The fundamental fallacy in petitioner’s argument is that the situation here is, in all material respects, unlike that in Brown v. Routzahn, supra.

Berger v. Commissioner

37 T.C. 1026 · United States Tax Court · Mar 6, 1962

They cite United States v. Lewis, 340 U.S. 590 , and Healy v. … These same parties constituted the entire board of directors and they authorized the payment to themselves in 1953 and 1954 the salaries which the respondent found to be excessive in part. In Figge v.

Iglesias v. Commissioner

76 T.C. 1060 · United States Tax Court · Jun 25, 1981

See, e.g., Adams v. Commissioner, 71 T.C. 477 (1978); Rosenthal v. Commissioner, 68 T.C. 454 (1975); Dietz v. Commissioner, 62 T.C. 578 (1974); Fisher v. Commissioner, 56 T.C. 1201 (1971). … In Voigt v.

Breman v. Commissioner

66 T.C. 61 · United States Tax Court · Apr 8, 1976

The Court, in Cirillo v. … The case of Papa v.

Maltine Co. v. Commissioner

5 T.C. 1265 · United States Tax Court · Dec 19, 1945

The petitioner urges that the decision of the Board of Tax Appeals in Maltine Co. v. Commissioner, Docket Nos. 2805 and 3967, promulgated February 18, 1927, and reported at 6 B. T. … C. 789 ; Pelham Hall Co. v. Eassett, 147 Fed. (2d) 63.

Del Mar Turf Club v. Commissioner

16 T.C. 749 · United States Tax Court · Apr 12, 1951

No member of the Racing Board testified in this case. The attorney for petitioner talked to Mr. … C. 1265 , 1274 (1948); Commissioner’s Bulletin on Section 722, Part V, Subpart II.

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.

Olson v. Commissioner

48 T.C. 855 · United States Tax Court · Sep 21, 1967

As was said in Commissioner v. … Zenz v. Quinlivan, supra; United States v. Cumberland Pub. Serv. Co., supra.

Columbia Park & Recreation Asso. v. Commissioner

88 T.C. 1 · United States Tax Court · Jan 6, 1987

Residents of Columbia elect 16 representatives annually who make up petitioner’s board of directors (board). 32 The board is responsible for formulating policy as well as budget and financial matters. … About five resident groups including village boards and various resident advisory committees assist the board. The village boards are the governing element of village associations.

Hotel Equities Corp. v. Commissioner

65 T.C. 528 · United States Tax Court · Dec 15, 1975

In Phinney v. … v.

Atwood Grain & Supply Co. v. Commissioner

60 T.C. 412 · United States Tax Court · Jun 12, 1973

See also Raley v. United States, an unreported case (M.D. Fla. 1912, 31 A.F.T.R. 2d 73 -326, 72-2 U.S.T.C. par. 9739). … In Ketler v.

Gerling International Ins. Co. v. Commissioner

86 T.C. 468 · United States Tax Court · Mar 26, 1986

Supplementary Answer As previously disclosed, Robert Gerling was and is chairman of Universale’s Board of Administrators (the Board). The Board is a supervisory body which acts only by resolution of the majority. … Marx v.

F. W. Woolworth Co. v. Commissioner

54 T.C. 1233 · United States Tax Court · Jun 15, 1970

Woolworth Co. v. … Petitioner’s two members of the British subsidiary’s board of directors did not regularly attend the meetings of the British subsidiary’s board of directors.