Category: United States Tax Court Opinions

ESTATE OF SCHARF v. COMMISSIONER OF INTERNAL REVENUE, 38 T.C. 15 (1962) ESTATE OF GRACE M. SCHARF, DECEASED, CHARLES E. SCHARF AND ARTHUR A.SCHARF, COEXECUTORS, ET AL.,[fn1] PETITIONERS, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket Nos. 71277, 71317, 71318.United States Tax Court. Filed April 6, 1962. [fn1] Proceedings of the following petitioners are consolidated herewith: Arthur […]

BAVIS v. COMMISSIONER OF INTERNAL REVENUE, 18 T.C. 418 (1952) FRANK R. BAVIS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT.THOMAS F. BELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT.DONATO A. GIANGIULIO, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket Nos. 26414, 26734, 27398.United States Tax Court. Promulgated May 29, 1952. Petitioners, key employees of the Chichester Chemical Company […]

MATTHEWS v. COMMISSIONER OF INTERNAL REVENUE, 8 T.C. 1313 (1947) CHARLES J. MATTHEWS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 7979.United States Tax Court. Promulgated June 27, 1947. Petitioner in 1930 guaranteed the stock margin trading account of his secretary. In 1941 he paid $31,372.44 under the guaranty. Later in 1941 he married his […]

OWENS v. COMMISSIONER OF INTERNAL REVENUE, 26 T.C. 77 (1956) MARIE R. OWENS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 29571.United States Tax Court. Filed April 16, 1956. 1. Petitioner, with her husband, Leo, and their children, was domiciled in St. Paul, Minnesota, prior to 1939. Leo had been a newspaper publisher and after […]

PENICK v. COMMISSIONER OF INTERNAL REVENUE, 37 T.C. 999 (1962) MARGARET H. D. PENICK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 75658.United States Tax Court. Filed February 27, 1962. Held, that the payments made to petitioner in 1955 and 1956 by S. B. Penick Company were not made to her as gifts and were […]

GUSTAFSON v. COMMISSIONER OF INTERNAL REVENUE, 97 T.C. 85 (1991) RUSSELL F. AND BARBARA B. GUSTAFSON, PETITIONERS v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. No. 300-91.United States Tax Court. Filed July 29, 1991. In September 1989, petitioners commenced a case contesting respondent’s deficiency determination for 1986. Respondent conceded that case, and a stipulated decision was entered in […]

LaMASTRO v. COMMISSIONER, 72 T.C. 377 (1979) ANTHONY LaMASTRO AND HELEN LaMASTRO, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 1594-74.United States Tax Court. Filed May 23, 1979. Petitioner husband formed a professional corporation which elected subchapter S status. During its first taxable year, encompassing 14 days, the corporation adopted a pension plan and made […]

SEYBURN v. COMMISSIONER OF INTERNAL REVENUE, 51 T.C. 578 (1969) GEORGE D. SEYBURN AND FLORENCE SEYBURN, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket No. 6968-65.United States Tax Court. Filed January 9, 1969. Petitioner attempted to assign to two charities a portion of his interest in a partnership business subsequent to the sale and distribution of […]

1432 BROADWAY CORP. v. COMMR. OF INTERNAL REVENUE, 4 T.C. 1158 (1945) 1432 BROADWAY CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 1828.United States Tax Court. Promulgated April 20, 1945. Amounts accrued by a corporation as interest on debentures issued to its shareholders with shares at the time of incorporation, held, under the circumstances, […]

CARNEGIE CENTER CO. v. COMMR. OF INTERNAL REVENUE, 22 T.C. 1189 (1954) THE CARNEGIE CENTER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 30353.United States Tax Court. Filed September 17, 1954. DEDUCTION — DEPRECIATION — BASIS — BASIS OF BUILDINGS DOES NOT INCLUDE SEPARATE IDENTIFIABLE COST OF ACQUIRING FEE. — The basis for depreciation […]