Case law

Central Inv. Corp. v. Commissioner

9 T.C. 128 · United States Tax Court · Jul 30, 1947

In Magruder v. Supplee, supra, for instance, the taxpayer-vendee purchased real property on May 10, 1936. … United States v. Anderson, 269 U. S. 422 ; Petaluma & Santa Rosa R. R. Co., 11 B. T. A. 541; H. H. Brown Co., 8 B. T. A. 112; Durst Productions Corporation, 8 T. C. 1326 .

Preston v. Commissioner

14 T.C. 1391 · United States Tax Court · Jun 30, 1950

That question was not before the Board of Tax Appeals in Preston’s case. And if petitioner stresses the rationale of the opinion in that proceeding, complete answer is found to such argument in Commissioner v. … E. 135 ; Heyman v. Heyman, 33 N. Y. S. (2d) 235; Osborn v. Banker's Trust Co., 5 N. Y. S. (2d) 211. Reference has been made in this proceeding to the Appellate Division’s decision in United States Trust Company v.

Freeman v. Commissioner

36 T.C. 779 · United States Tax Court · Jul 31, 1961

Commissioner v. Court Holding Co., 324 U.S. 331 (1945), and United States v. Cumberland Publ. Serv. Co., 338 U.S. 451 (1950). … See Caldwell v. United States, 114 F. 2d 995 (C.A. 3, 1940); Georgia-Florida Land Co., 16 B.T.A. 1253 (1929); J. W. Elmore, 15 B.T.A. 1210 (1929).

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).

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.

Connell v. Commissioner

20 T.C. 917 · United States Tax Court · Aug 25, 1953

A. 2) 98 F. 2d 62 , affirming the Board of Tax Appeals, 35 B. T. A. 916; and to Johnson v. Commissioner, (C. A. 2) 86 F. 2d 710 , cited and followed in the Guaranty case. … Under the circumstances, as the Board stated in the Guaranty case: The courts and this Board have looked through the forms of transactions to their substance, particularly where an effort to reduce or avoid the payment of

Estate of Peterson v. Commissioner

74 T.C. 630 · United States Tax Court · Jul 7, 1980

The described calves are now situated on ranches in Brown County and Holt County, in Nebraska. … See Keck v.

Cobb v. Commissioner

13 T.C. 495 · United States Tax Court · Sep 30, 1949

The Supreme Court of the United States, in Culbertson v. Commissioner, 337 U. … To the same effect see Commissioner v. Tower, 327 U. S. 280 .

Lincoln Electric Co. v. Commissioner

54 T.C. 926 · United States Tax Court · May 6, 1970

Photo-Sonics, Inc. v. Commissioner, 357 F. 2d 656 (C.A. 9, 1966), affirming 42 T.C. 926 (1964); Fort Howard Paper Co., 49 T.C. 275, 286, 287 (1967). … Commissioner v. Hansen, 360 U.S. 446 (1959).

Deyoe v. Commissioner

66 T.C. 904 · United States Tax Court · Aug 30, 1976

T.C. par. 54,012 (1953), and Maurine DeWolfe Brown, 12 T.C.M. 948 , 22 P-H Memo. … Maurine DeWoife Brown, supra at 952-953 .

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.

Martin Weiner Corp. v. Commissioner

21 T.C. 470 · United States Tax Court · Jan 15, 1954

A. 1396, and Superheater Co. v. Commissioner., 125 F. 2d 514 . … Decision will be entered v/nder Bule 50.

Premier Products Co. v. Commissioner

2 T.C. 445 · United States Tax Court · Jul 21, 1943

Premier Products Company, Petitioner, v. Commissioner of Internal Revenue, Respondent. Estate of William D. McCullough, Deceased, John J. Browne and John F. Linehan, Executors, Petitioner, v. … The decisions of such special division shall not be reviewable by the Board, and shall be deemed decisions of the Board."

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).

New Jersey Title Guarantee & Trust Co. v. Commissioner

13 T.C. 674 · United States Tax Court · Oct 31, 1949

United States v. … Simply because, in connection with the period of limitation, United States v. Updike, supra, or with the right to appeal to the Board of Tax Appeals, Henry Cappellini, 14 B. T.

Breman v. Commissioner

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

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

Wynekoop v. Commissioner

24 T.C. 167 · United States Tax Court · May 6, 1955

based on the Board’s inclusion of the ordinary trust income, it is necessary to state that one of these New York trusts was construed in Morris v. … See Freuler v. Helvering, 291 U. S. 35 (1934); Blair v. Commissioner, 300 U. S. 5 (1937); and Sharp v. Commissioner, 303 U.

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.

Crown v. Commissioner

58 T.C. 825 · United States Tax Court · Aug 14, 1972

Co. v. … Similarly, in Schaffner v.

Manning v. Commissioner

3 T.C. 853 · United States Tax Court · May 17, 1944

Andrews v. St. Louis Joint Stock Land Bank, 107 Fed. (2d) 462, 467. … These expenditures in 1939 were incident to litigation before the United States Board of Tax Appeals in 1936, and to an appeal which was taken from the decision of the Board.