Category: United States Tax Court Opinions

CITY INVESTING CO. v. COMMISSIONER OF INTERNAL REVENUE, 38 T.C. 1 (1962) CITY INVESTING COMPANY AND SUBSIDIARIES, PETITIONERS, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket No. 83591.United States Tax Court. Filed April 3, 1962. Pursuant to a policy of liquidating its property holdings in Lower Manhattan, T corporation in 1950 transferred its fee simple interest in […]

NICHOLSON v. COMMISSIONER OF INTERNAL REVENUE, 3 T.C. 596 (1944) GEORGE JAMES NICHOLSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT.GEORGE J. NICHOLSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket Nos. 109954, 112307.United States Tax Court. Promulgated April 10, 1944. 1. In determining a gift tax for 1940, the Commissioner held that prior gifts in 1935 were […]

McCORKLE v. COMMISSIONER, 124 T.C. 56 (2005) WILLIAM J. McCORKLE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 1433-03L.United States Tax Court. Filed February 24, 2005. R’s Appeals Office determined that R was warranted in filing a notice of Federal tax lien (NFTL) against P with respect to his 1996 Federal income tax liability. P […]

BURR OAKS CORP. v. COMMISSIONER OF INTERNAL REVENUE, 43 T.C. 635 (1965) BURR OAKS CORPORATION, ET AL.,[fn1] PETITIONERS, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket Nos. 4771-62, 4772-62, 1581-63, 1583-63.United States Tax Court. Filed February 11, 1965. [fn1] Proceedings of the following petitioners are consolidated herewith: A. Aaron Elkind and Rosella Elkind, docket No. 4772-62; Harold […]

DI BORGO v. COMMISSIONER OF INTERNAL REVENUE, 23 T.C. 76 (1954) VALERIE NORRIE POZZO DI BORGO, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 47528.United States Tax Court. Filed October 15, 1954. Petitioner in 1949 paid commissions to a trustee upon the revocation of a trust previously created by her. The total amount of the […]

HAYNSWORTH v. COMMISSIONER, 68 T.C. 703 (1977) ROBERT F. AND HAZEL HAYNSWORTH, PETITIONERS v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket No. 5501-75.United States Tax Court. Filed August 22, 1977. In 1959, a partnership of which petitioner-husband was a member acquired a piece of land for subdivision purposes, obtained an estimate of the costs of developing it, […]

KELBY v. COMMISSIONER, 130 T.C. 79 (2006) RICHARD AND MABEL KELBY, PETITIONERS v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket No. 13268-03L.United States Tax Court. Filed April 28, 2008. Ps petitioned this Court for review of a notice of determination issued under sec. 6330, I.R.C. Thereafter, the case was remanded to R’s Appeals Office three times; each […]

ESTATE OF CAPORELLA v. COMMISSIONER OF INTERNAL REVENUE, 86 T.C. 285 (1986) ESTATE OF JOSEPH CAPORELLA, DECEASED, NICK A. CAPORELLA, PERSONALREPRESENTATIVE, AND JEAN CAPORELLA, PETITIONERS v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. No. 5213-83.United States Tax Court. Filed March 4, 1986. The Caporellas reported losses from a horse breeding activity. In order to avail themselves of the […]

SOUTH PENN OIL CO. v. COMMISSIONER OF INTERNAL REVENUE, 17 T.C. 27 (1951) SOUTH PENN OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 21975.United States Tax Court. Promulgated July 17, 1951. 1. A trust, forming part of a pension plan, was created by petitioner in 1933, within the meaning of section 165 (a), […]

LUNSFORD v. COMMISSIONER OF INTERNAL REVENUE, 117 T.C. 159 (2001) JOSEPH D. AND WANDA S. LUNSFORD, Petitioners v. COMMISSIONER OF INTERNALREVENUE, Respondent Docket No. 18071-99L.United States Tax Court. Filed November 30, 2001. R issued a notice of intent to levy, and Ps requested a hearing before an IRS Appeals officer (A) pursuant to sec. 6330, […]