ALLEN TOOL CORP. v. FRANK KNOX, 3 T.C. 847 (1944) ALLEN TOOL CORPORATION, PETITIONER, v. FRANK KNOX, SECRETARY OF THE NAVYOF THE UNITED STATES, RESPONDENT. Docket No. 1 R.United States Tax Court. Promulgated May 15, 1944. PROCEDURE — RENEGOTIATION — RULE 64. — Petitions based upon a unilateral order should conform as nearly as possible […]
Category: United States Tax Court Opinions
FEASTER v. COMMISSIONER, 2010-157 (T.C. 7-22-2010)
FEASTER v. COMMISSIONER, 2010-157 (T.C. 7-22-2010) DANIEL FEASTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,Respondent. No. 2296-09.United States Tax Court. Filed July 22, 2010. MEMORANDUM FINDINGS OF FACT AND OPINION Daniel Feaster, pro se. David M. McCallum, for respondent. COHEN, Judge: Respondent determined a deficiency of $1,387 in petitioner’s 2006 Federal income tax. The issue for […]
MOSELEY v. COMMISSIONER, 72 T.C. 183 (1979)
MOSELEY v. COMMISSIONER, 72 T.C. 183 (1979) NED W. MOSELEY AND MABEL BOWMAN MOSELEY, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 925-76.United States Tax Court. Filed April 23, 1979. Petitioner received a distribution under the “special reserve” provision of a life insurance contract which provided, in addition, for a $5,000 life insurance benefit. Under […]
THRIFTIMART, INC. v. COMMISSIONER OF INTERNAL REVENUE, 59 T.C. 598 (1973)
THRIFTIMART, INC. v. COMMISSIONER OF INTERNAL REVENUE, 59 T.C. 598 (1973) THRIFTIMART, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 3079-69.United States Tax Court. Filed January 31, 1973. Held: 1. Petitioner, an accrual basis taxpayer, which is a self-insurer under the California Workmen’s Compensation law is not entitled to deduct a reserve for estimated […]
VAN HUMMELL v. COMMISSIONER OF INTERNAL REVENUE, 3 T.C. 101 (1944)
VAN HUMMELL v. COMMISSIONER OF INTERNAL REVENUE, 3 T.C. 101 (1944) HENRY VAN HUMMELL, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 1350.United States Tax Court. Promulgated January 22, 1944. Petitioner’s income during the taxable year was “ascribed primarily” to the activities of V, who owned two-thirds of its stock, and to the activities […]
B. C. COOK SONS, INC. v. COMMR. OF INTERNAL REVENUE, 65 T.C. 422 (1975)
B. C. COOK SONS, INC. v. COMMR. OF INTERNAL REVENUE, 65 T.C. 422 (1975) B. C. COOK SONS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 1009-74.United States Tax Court. Filed December 1, 1975. A decision of this Court allowed a corporation an embezzlement loss deduction for 1965. A portion of said loss had […]
SIMMONS v. COMMISSIONER, 2009-283 (T.C. 12-9-2009)
SIMMONS v. COMMISSIONER, 2009-283 (T.C. 12-9-2009) DAVID L. SIMMONS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,Respondent. No. 9527-07.United States Tax Court. Filed December 9, 2009. David L. Simmons, pro se. Joel D. McMahan, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined the following deficiencies in petitioner’s Federal income taxes and additions to […]
UNIQUE ART MFG. CO., INC. v. COMMR. OF INTERNAL REV., 8 T.C. 1341 (1947)
UNIQUE ART MFG. CO., INC. v. COMMR. OF INTERNAL REV., 8 T.C. 1341 (1947) UNIQUE ART MANUFACTURING COMPANY, INC., PETITIONER, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket No. 9295.United States Tax Court. Promulgated June 30, 1947. Petitioner in its base period was indebted to corporation B on certain bonds and mortgages. It purchased on the market […]
TURNER v. COMMISSIONER OF INTERNAL REVENUE, 56 T.C. 27 (1971)
TURNER v. COMMISSIONER OF INTERNAL REVENUE, 56 T.C. 27 (1971) WILLIAM B. TURNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 4374-68.United States Tax Court. Filed April 8, 1971. During 1966 petitioner was a temporary corporate employee who daily traveled considerable distances by automobile to work and home again. Held, petitioner is a commuter, and […]
SWOPE v. COMMISSIONER OF INTERNAL REVENUE, 51 T.C. 442 (1968)
SWOPE v. COMMISSIONER OF INTERNAL REVENUE, 51 T.C. 442 (1968) WILLIAM B. SWOPE AND VIRGINIA M. SWOPE, ET AL.,[fn1] PETITIONERS v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket Nos. 3680-66-3682-66.United States Tax Court. Filed December 19, 1968. [fn1] Cases of the following petitioners are consolidated herewith: Paul W. Jones and Merla C. Jones, docket No. 3681-66, and […]