Category: United States Tax Court Opinions

ASHE v. COMMISSIONER OF INTERNAL REVENUE, 33 T.C. 331 (1959) WILLIAM F. ASHE AND KATHLEEN L. ASHE, PETITIONERS, v COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket No. 68441.United States Tax Court. Filed November 27, 1959. Pursuant to the terms of an agreement incorporated into a decree of divorce, petitioner was obliged to pay his former wife $250 […]

MARTZ v. COMMISSIONER OF INTERNAL REVENUE, 77 T.C. 749 (1981) HAROLD J. MARTZ AND POLLY I. MARTZ, PETITIONERS v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. No. 16906-80.United States Tax Court. Filed October 1, 1981. Held, in determining whether respondent has asserted a deficiency under sec. 6211, I.R.C. 1954, respondent’s adjustments to petitioners’ investment credit must be considered […]

SANGERS HOME FOR CHRONIC PATIENTS v. COMMISSIONER, 72 T.C. 105 (1979) SANGERS HOME FOR CHRONIC PATIENTS, INC., PETITIONER v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENTCHARLES EKBLOM AND ELIZABETH SANGER EKBLOM, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket Nos. 8984-74, 9110-74.United States Tax Court. Filed April 11, 1979. Held, petitioners are precluded by applying the doctrine of equitable […]

LARCHMONT FOUNDATION, INC. v. COMMISSIONER, 72 T.C. 131 (1979) LARCHMONT FOUNDATION, INC., AND PAUL R. STOUT, PETITIONERS v. COMMISSIONEROF INTERNAL REVENUE, RESPONDENT Docket No. 9860-75.United States Tax Court. Filed April 17, 1979. P was the president of F, a private foundation. The Commissioner determined that disbursements listed on F’s return for 1971 were taxable expenditures […]

SCHULTZ v. COMMISSIONER OF INTERNAL REVENUE, 59 T.C. 559 (1973) MORTIMER L. SCHULTZ AND ROSANNA SCHULTZ, ET AL.,[fn1] PETITIONERS v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket Nos. 1830-71 — 1834-71.United States Tax Court. Filed January 22, 1973. [fn1] Cases of the following petitioners are consolidated herewith: Rosanna Schultz, Custodian for Roger Schultz, docket No. 1831-72; Rosanna […]

DILLARD PAPER CO. v. COMMISSIONER OF INTERNAL REVENUE, 42 T.C. 588 (1964) DILLARD PAPER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 2804-62.United States Tax Court. Filed June 17, 1964. Held, long-term capital loss in the amount of $12,918.87 realized upon the transfer of securities by petitioner to the fiduciary of its employees’ profit-sharing […]

MISHAWAKA PROPERTIES CO. v. COMMR. OF INTERNAL REVENUE, 100 T.C. 353 (1993) MISHAWAKA PROPERTIES CO., EDMOND A. MALOUF, SR., TAX MATTERS PARTNER,PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. No. 13384-88.United States Tax Court. Filed April 13, 1993. A participating partner in a TEFRA partnership proceeding filed a motion to dismiss for lack of jurisdiction because […]

COLUMBIA TOOL STEEL CO. v. COMMR. OF INTERNAL REVENUE, 27 T.C. 70 (1956) COLUMBIA TOOL STEEL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 29705.United States Tax Court. Filed October 22, 1956. Petitioner, a tool steel manufacturer, which, during 1941, increased its capacity for production pursuant to a course of action to which it […]

HOME TITLE GUARANTY CO. v. COMMR. OF INTERNAL REVENUE, 15 T.C. 637 (1950) HOME TITLE GUARANTY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 20631.United States Tax Court. Promulgated November 16, 1950. Petitioner, a New York corporation, is subject to taxation as an insurance company under section 204 of the Internal Revenue Code. From […]