Category: United States Tax Court Opinions

ESTATE OF ESPOSITO v. COMMISSIONER OF INTERNAL REVENUE, 40 T.C. 459 (1963) ESTATE OF JOSEPH R. ESPOSITO, ERWIN BRUCE HALLETT, JAMES BECKETT ANDRUSSELL GOWANS, EXECUTORS, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket No. 92346.United States Tax Court. Filed May 31, 1963. CHARITABLE DEDUCTION — CONSENT DIVIDEND UNDER SEC. 565, I.R.C. 1954. — An amount reported […]

BROOKS v. COMMISSIONER OF INTERNAL REVENUE, 82 T.C. 413 (1984) GLENN D. BROOKS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. No. 4370-80.United States Tax Court. Filed March 8, 1984. Respondent determined deficiencies totaling $123,582.09 and additions to tax for fraud under sec. 6653 (b), I.R.C. 1954, totaling $61,791.06, for the years 1967 through 1973. The […]

MILES v. COMMISSIONER OF INTERNAL REVENUE, 31 T.C. 1001 (1959) EGBERT J. MILES AND JEAN N. MILES, PETITIONERS, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket No. 67209.United States Tax Court. Filed February 13, 1959. In 1953 petitioner embarked upon a series of transactions which in form were as follows. Petitioner purchased $175,000-face-value United States Treasury bonds […]

K. C. SOUTHERN INDUS. v. COMMR., I. R. S., 98 T.C. 242 (1992) KANSAS CITY SOUTHERN INDUSTRIES, INC., PETITIONER v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Nos. 18653-87, 17654-88.United States Tax Court. Filed March 5, 1992. P was the parent of members of a consolidated group, including two subsidiaries conducting railroad operations. For the taxable calendar years […]

F. D. BISSETT SON v. COMMR. OF INTERNAL REVENUE, 56 T.C. 453 (1971) F. D. BISSETT SON, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 295-69.United States Tax Court. Filed June 1, 1971. Petitioner deducted $5,500 in interest accrued in connection with certain of its debentures in each of the taxable years 1965, 1966, […]

BOWEN v. COMMISSIONER OF INTERNAL REVENUE, 34 T.C. 222 (1960) MARTIN RAYMOND BOWEN, ET AL.,[fn1] PETITIONERS, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket Nos. 69452, 69453, 69454.United States Tax Court. Filed May 17, 1960. [fn1] Proceedings of the following petitioners are ordered consolidated herewith for the purposes of this opinion: Mary Jane Tucker, Docket No. 69453, […]

BECKER v. COMMISSIONER OF INTERNAL REVENUE, 85 T.C. 291 (1985) WILLIAM L. BECKER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. No. 8498-80.United States Tax Court. Filed August 15, 1985. On remand from the Court of Appeals for the Third Circuit (751 F.2d 146 (1984)): Held, the distinction created by the Commissioner in Rev. Rul. 80-173, 1980-2 […]

MANDLER v. COMMISSIONER OF INTERNAL REVENUE, 65 T.C. 586 (1975) SYDNEY MANDLER AND ELAINE S. MANDLER, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENTSANDOR SPECTOR AND ELAINE R. SPECTOR, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket Nos. 1698-71, 1699-71.United States Tax Court. Filed December 18, 1975. Petitioners’ subch. S corporation owned and operated coin-activated laundry facilities in […]

ESTATE OF KAHR v. COMMISSIONER OF INTERNAL REVENUE, 48 T.C. 929 (1967) ESTATE OF WILLIAM KAHR (A.K.A. WILLIAM CARR), DECEASED, JAMES F. DALTON,EXECUTOR, AND MARY ZANGERLE (FORMERLY KNOWN AS MARY K. KAHR AND MARYCARR), SURVIVING WIFE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 1281-65.United States Tax Court. Filed September 29, 1967. Taxpayer pursued a […]

HOCKADEN ASSOCIATES v. COMMISSIONER OF INTERNAL REVENUE, 84 T.C. 13 (1985) HOCKADEN ASSOCIATES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. No. 8003-83.United States Tax Court. Filed January 9, 1985. P obtained certain loans from its tax-exempt employee profit-sharing plan prior to Jan. 1, 1975, and the loans remained outstanding after that date. Held, P is […]