Category: United States Tax Court Opinions

BEAUSOLEIL v. COMMISSIONER OF INTERNAL REVENUE, 66 T.C. 244 (1976) WILLIAM F. BEAUSOLEIL AND FLORENCE M. BEAUSOLEIL, PETITIONERS v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 1384-75.United States Tax Court. Filed May 13, 1976. Held, a $1,600 Invention Achievement Award received by petitioner from his employer was additional compensation taxable as ordinary income under sec. 61(a)(1), […]

SCHIFFMAN v. COMMISSIONER OF INTERNAL REVENUE, 47 T.C. 537 (1967) ALLEN SCHIFFMAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT United States Tax Court. Docket No. 5992-65. Filed February 28, 1967. Petitioner, a general insurance agent, gave either a discount or rebate to customers and retained a correspondingly lesser amount as his commission, remitting the full net […]

RANZ v. COMMISSIONER OF INTERNAL REVENUE, 31 T.C. 91 (1958) FRANK STEPHEN RANZ, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 65184.United States Tax Court. Filed October 17, 1958. Petitioner, a professional engineer and sales representative of machine tool manufacturers in an area including Cincinnati, Ohio, entered into an informal contract with the Rehnberg-Jacobson Manufacturing […]

FOUNDATION v. COMMISSIONER OF INTERNAL REVENUE, 48 T.C. 963 (1967) CURT TEICH FOUNDATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENTCURT TEICH, SR., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket Nos. 938-65, 939-65.United States Tax Court. Filed September 29, 1967. Petitioner Teich, Sr., donated $1.2 million so-called blue chip securities to foundation in June 1960. In July […]

TAYLOR-WHARTON IRON STEEL v. COMMR. OF INTERNAL REV., 5 T.C. 768 (1945) TAYLOR-WHARTON IRON AND STEEL CO., PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 4387.United States Tax Court. Promulgated September 20, 1945. 1. Petitioner in 1935 liquidated wholly owned subsidiaries whose operating losses in prior years had been availed of by petitioner in consolidated […]

SMOKY MOUNTAINS BEVERAGE v. COMMR. OF INTERNAL REV., 22 T.C. 1249 (1954) SMOKY MOUNTAINS BEVERAGE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket Nos. 21778, 26761.United States Tax Court. Filed September 23, 1954. 1. Held, salaries and bonuses which petitioner paid to two of its officers in the taxable years involved represented reasonable compensation for […]

GORDON v. COMMISSIONER OF INTERNAL REVENUE, 29 T.C. 510 (1957) DAVID L. GORDON AND CLARE (CLARA) B. GORDON, PETITIONERS, v. COMMISSIONEROF INTERNAL REVENUE, RESPONDENT.WILLIAM C. HILDEBRAND, JR., AND JACQUELINE HILDEBRAND, PETITIONERS, v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket Nos. 54063, 54064.United States Tax Court. Filed December 24, 1957. In 1950, petitioners received a lump-sum commutation payment […]

PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONS, 19 T.C. 1241 (1953)United States Tax Court. 1953. PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONS Docket No. Title 33290 Algy, Inc. 34322 Allen, Herbert, and Wife 33032 Ambuhl, Frances 34480 Armstrong, R. J., Co. 36427 Arnold, N.J. 33100 Auer, John, and Wife 31476 Beels, Raymond F. 31683 Belford, Robert Lee, […]

DOWNEY v. COMMISSIONER OF INTERNAL REVENUE, 97 T.C. 150 (1991) BURNS P. DOWNEY AND MARJORIE DOWNEY, PETITIONERS v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. No. 11120-89.United States Tax Court. Filed July 31, 1991. P, an airline pilot, sued his former employer under the Age Discrimination in Employment Act of 1967 (ADEA) claiming that certain actions of his […]

DOLAN v. COMMISSIONER OF INTERNAL REVENUE, 44 T.C. 420 (1965) MARIE A. DOLAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 4892-62.United States Tax Court. Filed June 23, 1965. 1. Petitioner’s claim that her signatures on 1957 and 1958 Federal income tax returns headed “John T. Marie A. Dolan” were forged or procured by fraud […]