Category: United States Tax Court Opinions

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 […]

DEAL v. COMMISSIONER OF INTERNAL REVENUE, 29 T.C. 730 (1958) MINNIE E. DEAL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 61801.United States Tax Court. Filed January 29, 1958. Petitioner, on December 29, 1952, transferred land with a market value of $66,000 in trust. The trustees in their discretion were to pay to the petitioner […]

MIDLAND ELEC. COAL CORP. v. COMMR. OF INTERNAL REVENUE, 3 T.C. 182 (1944) MIDLAND ELECTRIC COAL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 104657.United States Tax Court. Promulgated January 31, 1944. Petitioner, by certain written contracts entered into with its creditors in 1935, promised that so long as certain of its notes were […]

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 […]

HOOPER CONSTRUCTION CO. v. RENEGOTIATION BOARD, 35 T.C. 837 (1961) HOOPER CONSTRUCTION COMPANY, A CORPORATION, PETITIONER, v. RENEGOTIATIONBOARD, RESPONDENT. Docket No. 951-R.United States Tax Court. Filed February 28, 1961. Petitioner, whose regular method of accounting, on which it reported its income for Federal income tax purposes, was an accrual and completed contract basis, completed all […]

ESTATE OF ALLEN v. COMMISSIONER OF INTERNAL REVENUE, 6 T.C. 597 (1946) ESTATE OF WILLIAM P. ALLEN, FIDUCIARY TRUST COMPANY OF NEW YORK,CO-EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket No. 6059.United States Tax Court. Promulgated March 29, 1946. Under a testamentary trust all income was to be distributed currently to the life beneficiary, […]

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 […]