Case law

Estate of Hornor v. Commissioner

36 T.C. 337 · United States Tax Court · May 24, 1961

William’s estate timely filed with the Court of Appeals for the Third Circuit a petition for review of the decision of the Board. The Court of Appeals in Hornor's Estate v. … The petitioner, resting on the foregoing position and relying on Bull v. United States, 295 U.S. 247 (1935), and Stone v.

Sidles v. Commissioner

19 T.C. 1114 · United States Tax Court · Mar 24, 1953

Varney v. Ditmars, 111 N. E. 822 . … C. 9 ; Zwolanek v. Baker Mfg. Co., 187 N. W. 769, 772 .

Hotel Equities Corp. v. Commissioner

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

In Phinney v. … v.

Landreth v. Commissioner

50 T.C. 803 · United States Tax Court · Sep 4, 1968

Yet, it would follow a fortiori from Commissioner v. Brown, 380 U.S. 563 (1965), that such a sale on credit would be recognized as a sale for tax purposes. … Under Commissioner v. Brown, it is clear, as we have already shown, that the assumption of such a guarantee by a seller does not vitiate the sale.

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.

Romanelli v. Commissioner

54 T.C. 1448 · United States Tax Court · Jul 2, 1970

In that case, four officers entered defendant’s bedroom, in a boarding house at which he lodged, and briefly questioned him. … Brown v. Walker, 161 U.S. 591 (1896); Brown v. United States, 359 U.S. 41 (1959) Mason v. United States, 244 U.S. 362 (1917).

Payson v. Commissioner

18 T.C.M. 686 · United States Tax Court · Aug 13, 1959

Herbert Payson, Jr. and Eileen Payson, Husband and Wife v. Commissioner. Benjamin D. Holt and Anne Carroll Holt, Husband and Wife v. Commissioner. Alida Payson Snow v. Commissioner. Payson v. … owned by the John Marshall Brown estate.

R. G. Le Tourneau, Inc. v. Administrator of General Services

22 T.C. 490 · United States Tax Court · Jun 7, 1954

Such agreements may contain such terms and conditions as the Board deems advisable. … C. 445 ), assessment and collection of interest on defaulted refunds (Greaves v. W. C. P. A. B., 10 T.

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

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.

Hammond v. Commissioner

20 T.C. 285 · United States Tax Court · Apr 30, 1953

See also York v. Commissioner, 160 F. 2d 385 . … Petitioner relies heavily on the case of Wallace v.

Sharp v. Commissioner

75 T.C. 32 · United States Tax Court · Oct 6, 1980

Petitioner and Brown J. Sharp (hereinafter Mr. Sharp) were married on May 24, 1957. On May 19, 1971, petitioner filed suit for divorce in the Fayette Circuit Court, Lexington, Fayette County, Ky. … See Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955); James v. United States, 366 U.S. 213 (1961).

Huff v. Commissioner

80 T.C. 804 · United States Tax Court · Apr 26, 1983

In Sachs v. … In People 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.

McCann v. Commissioner

2 T.C. 702 · United States Tax Court · Sep 17, 1943

S. 106 ; Lomb v. Sugden, 82 Fed. (2d) 166. … Decision will be entered v/nder Bule 60.

Faura v. Commissioner

73 T.C. 849 · United States Tax Court · Feb 19, 1980

Stubbs, Overbeck & Associates v. United States, 445 F.2d 1142, 1146-1147 (5th Cir. 1971); Browne v. Commissioner, 73 T.C. 723 (1980), (Hall, J., concurring); Minnis v. … Commissioner, 71 T.C. 1049, 1057 (1979), on appeal (5th Cir., June 22, 1979); Benninghoff v. Commissioner, 71 T.C. 216 , 222 n. 4 (1978), on appeal (5th Cir., Dec. 4, 1978); Estate of Lang v.

Hart-Bartlett-Sturtevant Grain Co. v. Commissioner

12 T.C. 760 · United States Tax Court · May 12, 1949

In Duesenberg, Inc. of Delaware v. Commissioner, 84 Fed. (2d) 921 (C. C. … The opinion of the Board in the earlier case was quoted in the opinion of the Board set forth in 40 B. T.

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.

Apple Computer, Inc. v. Commissioner

98 T.C. 232 · United States Tax Court · Mar 3, 1992

Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 544 (1979). … Commissioner v. LoBue, 351 U.S. 243, 247 (1956); Lighthill v. Commissioner, 66 T.C. 940, 946-948 (1976).

Willmott v. Commissioner

2 T.C. 321 · United States Tax Court · Jun 29, 1943

As the Supreme Court pointed out in Kornhauser v. United States, 276 U. … A. 1005; Higgins v. Commissioner, supra.