Category: United States Tax Court Opinions

WILSON v. COMMISSIONER OF INTERNAL REVENUE, 7 T.C. 1469 (1946) L. HELENA WILSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 5407.United States Tax Court. Promulgated December 31, 1946. Petitioner paid income tax in the Dominion of Canada on $20,000 received under a testamentary trust whose terms constituted such annual payment a legacy, as construed […]

PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONS, 57 T.C. 906 (1972)United States Tax Court. 1972. PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONST.C. Memo. Name 1971-265 Forsythe, Charles 1972-71 Frick, C. Frederick and Patricia B. 1971-259 Fuller, Dee L. and Georganna 1972-13 Fumigators, Inc. 1971-315 G C S Air Service, Inc. 1972-77 Glasgow, John D. and Karla Kay […]

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 […]

BRITISH TIMKEN LTD. v. COMMR. OF INTERNAL REVENUE, 12 T.C. 880 (1949) BRITISH TIMKEN LIMITED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 15210.United States Tax Court. Promulgated May 31, 1949. Prior to World War II, petitioner, a foreign corporation not engaged in trade or business within the United States, purchased roller bearings from an […]

DAVIS v. COMMISSIONER OF INTERNAL REVENUE, 64 T.C. 1034 (1975) EDWIN D. DAVIS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENTEDWIN D. DAVIS AND SANDRA W. DAVIS, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket Nos. 8665-71, 8666-71.United States Tax Court. Filed September 11, 1975. Petitioner Edwin D. Davis, an orthopedic surgeon, organized two corporations for performing […]

CHASTAIN v. COMMISSIONER OF INTERNAL REVENUE, 59 T.C. 461 (1972) THOMAS M. CHASTAIN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 7278-70.United States Tax Court. Filed December 27, 1972. At the time of his death (1964) D owned two mortgage notes upon the collection of which he would have realized long-term capital gains of $632,402.84 […]

AZAR NUT CO. v. COMMISSIONER OF INTERNAL REVENUE, 94 T.C. 455 (1990) AZAR NUT CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. No. 10416-88.United States Tax Court. Filed March 20, 1990. Pursuant to an employment contract, petitioner purchased for full market value ($285,000) a house owned by a terminated executive employee. Petitioner immediately tried to […]

MYERS v. COMMISSIONER OF INTERNAL REVENUE, 28 T.C. 12 (1957) CHARLES E. MYERS, SR., AND LILLIAN MYERS, PETITIONERS, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket No. 64218.United States Tax Court. Filed April 9, 1957. JURISDICTION — DEFICIENCY — DEFINITION — TAX IMPOSED BY CHAPTER 1, I. R. C. 1939 — SECS. 271 AND 294 (d). — […]