Category: United States Tax Court Opinions

BOMBARGER v. COMMISSIONER OF INTERNAL REVENUE, 31 T.C. 473 (1958) ZELTA J. BOMBARGER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 62530.United States Tax Court. Filed November 28, 1958. DEPENDENCY — SEC. 152 (a) (9), I. R. C. 1954. — Taxpayer and her minor son resided in home owned by another. Petitioner and homeowner, who […]

WILLARD HELBURN, INC. v. COMMR. OF INTERNAL REVENUE, 20 T.C. 740 (1953) WILLARD HELBURN, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 38865.United States Tax Court. Promulgated June 30, 1953. REALIZATION OF INCOME — FOREIGN FUNDS. — The petitioner borrowed pounds sterling in England in an amount sufficient to pay for lambskins to be […]

ESTATE OF RENSENHOUSE v. COMMR. OF INTERNAL REVENUE, 27 T.C. 107 (1956) ESTATE OF PROCTOR D. RENSENHOUSE, DECEASED, THE MICHIGAN TRUST COMPANY,EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket No. 57683.United States Tax Court. Filed October 22, 1956. Held, widow’s allowance granted by order of Michigan Probate Court not an interest in property passing […]

BLOOMINGTON TRANSMISSION SERV. v. COMMISSIONER, 87 T.C. 586 (1986) BLOOMINGTON TRANSMISSION SERVICES, INC., PETITIONER v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Nos. 13368-85, 39141-85.United States Tax Court. Filed September 4, 1986. P, an Illinois corporation, was dissolved for failure to pay franchise tax and to file an annual report. Illinois law limited P’s capacity to maintain a […]

WILMOT FLEMING ENG’G CO. v. COMMR. OF INTERNAL REV., 65 T.C. 847 (1976) WILMOT FLEMING ENGINEERING CO., ET AL.,[fn1] PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket Nos. 8657-73, 8757-73, 8758-73.United States Tax Court. Filed January 29, 1976. [fn1] The following cases are consolidated herewith: Wilmot E. Fleming and Pauline B. Fleming, docket No. 8757-73; and […]

WESTERN CASUALTY SURETY CO. v. COMMISSIONER, 65 T.C. 897 (1976) THE WESTERN CASUALTY AND SURETY COMPANY, PETITIONER v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 5971-72.United States Tax Court. Filed February 3, 1976. Held, petitioner, a stock fire and casualty insurance company taxable under sec. 831, I.R.C. 1954, is not entitled to include commissions on deferred […]

SHERWOOD PROPERTIES v. COMMISSIONER OF INTERNAL REVENUE, 89 T.C. 651 (1987) SHERWOOD PROPERTIES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Nos. 25018-83, 25019-83.United States Tax Court. Filed September 22, 1987. Freedland owned 89 percent of the stock of Freedland Ltd., a Canadian corporation. Freedland owned 50.01 percent and Sherwood owned 49.99 percent of the stock […]

HARBOR COVE MARINA PARTNERS PSHIP. v. COMMR., 123 T.C. 64 (2004) HARBOR COVE MARINA PARTNERS PARTNERSHIP, ROBERT A. COLLINS, A PARTNEROTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 13267-02.United States Tax Court. Filed July 15, 2004. H is a general partnership, its managing partner is S, and its other […]

HAASS v. COMMISSIONER OF INTERNAL REVENUE, 55 T.C. 43 (1970) ERWIN H. HAASS AND VIRGINIA A. HAASS, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 3146-68.United States Tax Court. Filed October 14, 1970. Petitioners, subsequent to the completion of two gas wells on certain property, entered into an oral agreement to participate in the drilling […]

PRIDEMARK, INC. v. COMMISSIONER OF INTERNAL REVENUE, 42 T.C. 510 (1964) PRIDEMARK, INC. (FORMERLY PREFAB HOMES AND SUPPLIERS, INC.), ET AL.,[fn1]PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket Nos. 93303-93307.United States Tax Court. Filed June 15, 1964. [fn1] The following cases are consolidated herewith: Pridemark, Inc., of Connecticut, docket No. 93304; Eugene Blitz and Eleanor […]