ASSOC. FOR ALTERNATIVE SCHOOLS v. COMMR., 71 T.C. 118 (1978) NATIONAL ASSOCIATION FOR THE LEGAL SUPPORT OF ALTERNATIVE SCHOOLS,PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 6844-77X.United States Tax Court. Filed November 6, 1978. Petitioner was formed as a nonprofit corporation to promote better education for children through expanded private educational opportunities and to […]
Category: United States Tax Court Opinions
DAVIS v. COMMISSIONER OF INTERNAL REVENUE, 66 T.C. 260 (1976)
DAVIS v. COMMISSIONER OF INTERNAL REVENUE, 66 T.C. 260 (1976) MACLIN P. DAVIS, JR., AND DOROTHY S. DAVIS; LAURENCE B. HOWARD, JR., ANDCORNEILLE T. HOWARD; ALLAN MURPHY AND ESTATE OF MARION E. MURPHY BY ALLANMURPHY, EXECUTOR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 2915-74.United States Tax Court. Filed May 17, 1976. Each of the […]
VIANELLO v. COMMISSIONER, 15967-07 (T.C. 2-1-2010)
VIANELLO v. COMMISSIONER, 15967-07 (T.C. 2-1-2010) MARC VIANELLO AND MICHELLE MULLARKEY VIANELLO, Petitioners v.COMMISSIONER OF INTERNAL REVENUE, Respondent No. 15967-07.United States Tax Court. Filed February 1, 2010. MEMORANDUM FINDINGS OF FACT AND OPINION John A. Beam III and J. Matthew Sharp, for petitioners. Dennis R. Onnen, for respondent. HAINES, Judge: Respondent determined deficiencies in petitioners’ […]
CARRIAGE SQUARE, INC. v. COMMISSIONER, 69 T.C. 119 (1977)
CARRIAGE SQUARE, INC. v. COMMISSIONER, 69 T.C. 119 (1977) CARRIAGE SQUARE, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 10635-75.United States Tax Court. Filed October 26, 1977. Petitioner was the only general partner of Sonoma and, as such, it provided all the services necessary for the conduct of the partnership business, contributed $556 to […]
ESTATE OF RAINGER v. COMMISSIONER OF INTERNAL REVENUE, 12 T.C. 483 (1949)
ESTATE OF RAINGER v. COMMISSIONER OF INTERNAL REVENUE, 12 T.C. 483 (1949) ESTATE OF RALPH RAINGER, DECEASED, ELIZABETH RAINGER, EXECUTRIX,PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket No. 8995.United States Tax Court. Promulgated March 30, 1949. 1. Decedent transferred all funds held as community property to the separate bank account of his wife in order […]
SHELL OIL CO., v. COMMISSIONER OF INTERNAL REVENUE, 89 T.C. 371 (1987)
SHELL OIL CO., v. COMMISSIONER OF INTERNAL REVENUE, 89 T.C. 371 (1987) SHELL OIL COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT.[fn*] No. 13180-84.United States Tax Court. Filed September 1, 1987. [fn*] Supplemental Opinion, 90 T.C. 747 (1988). Petitioner is an integrated oil company. Following the enactment of the Crude Oil Windfall Profit Tax Act of […]
DIXON v. COMMISSIONER, 132 T.C. No. 5 (T.C. 3-23-2009)
DIXON v. COMMISSIONER, 132 T.C. No. 5 (T.C. 3-23-2009) JERRY AND PATRICIA A. DIXON, ET AL.,[fn1] Petitioners v. COMMISSIONER OFINTERNAL REVENUE, Respondent. Nos. 9382-83, 15907-84, 30979-85.United States Tax Court. Filed March 23, 2009. [fn1] Cases of the following petitioners are consolidated herewith: Robert L. DuFresne and Carolyn S. DuFresne, docket Nos. 15907-84 and 30979-85. Ps’ […]
DUNN v. COMMISSIONER OF INTERNAL REVENUE, 42 T.C. 490 (1964)
DUNN v. COMMISSIONER OF INTERNAL REVENUE, 42 T.C. 490 (1964) JAMES D. DUNN AND JO ANN DUNN, PETITIONERS, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket No. 1315-62.United States Tax Court. Filed June 8, 1964. Petitioner, who was engaged in the business of buying and selling grain and renting grain-storage facilities, constructed certain special-purpose grain warehouses. He […]
BANKERS UNION LIFE INS. v. COMMR. OF INTERNAL REVENUE, 62 T.C. 661 (1974)
BANKERS UNION LIFE INS. v. COMMR. OF INTERNAL REVENUE, 62 T.C. 661 (1974) BANKERS UNION LIFE INSURANCE CO., PETITIONER v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket Nos. 5807-71, 442-73.United States Tax Court. Filed August 21, 1974. 1. Held: Deferred and uncollected premiums, including loading, are includable in “assets” under sec. 805(b)(4), I.R.C. 1954, for purposes of […]
PARKER v. COMMISSIONER OF INTERNAL REVENUE, 6 T.C. 974 (1946)
PARKER v. COMMISSIONER OF INTERNAL REVENUE, 6 T.C. 974 (1946) FRANCIS A. PARKER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 6387.United States Tax Court. Promulgated May 7, 1946. 1. Petitioner and his wife were carrying on a business together as a partnership in the State of Massachusetts during each of the taxable years. The […]