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, […]
Category: United States Tax Court Opinions
MISHAWAKA PROPERTIES CO. v. COMMR. OF INTERNAL REVENUE, 100 T.C. 353 (1993)
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 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 […]
MEARKLE v. COMMISSIONER OF INTERNAL REVENUE, 87 T.C. 527 (1986)
MEARKLE v. COMMISSIONER OF INTERNAL REVENUE, 87 T.C. 527 (1986) RUSSELL R. MEARKLE AND VIRGINIA R. MEARKLE, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. No. 28428-84.United States Tax Court. Filed August 25, 1986. After our decision in Scott v. Commissioner, 84 T.C. 683 (1985), in which the portion of the proposed regulation relied on by respondent […]
ESTATE OF VOGEL v. COMMISSIONER OF INTERNAL REVENUE, 30 T.C. 125 (1958)
ESTATE OF VOGEL v. COMMISSIONER OF INTERNAL REVENUE, 30 T.C. 125 (1958) ESTATE OF J. LESLIE VOGEL, ROBERT G. PARTRIDGE AND ELIZABETH S. VOGEL,EXECUTORS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket No. 57535.United States Tax Court. Filed April 28, 1958. 1. Held, the evidence failing to establish that a transmutation took place, respondent correctly […]
RELIANCE FACTORING CORP. v. COMMR. OF INTERNAL REVENUE, 15 T.C. 604 (1950)
RELIANCE FACTORING CORP. v. COMMR. OF INTERNAL REVENUE, 15 T.C. 604 (1950) RELIANCE FACTORING CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 20715.United States Tax Court. Promulgated November 10, 1950. Since its organization in 1935 petitioner has been engaged in the business of dealing in job lots, closeouts, odd lots and surplus material which […]
ESTATE OF CARLSON v. COMM. OF INTERNAL REVENUE, 21 T.C. 291 (1953)
ESTATE OF CARLSON v. COMM. OF INTERNAL REVENUE, 21 T.C. 291 (1953) ESTATE OF LEONARD O. CARLSON, N. A. CARLSON, EXECUTOR, PETITIONER, v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket No. 39615.United States Tax Court. Promulgated November 24, 1953. ESTATE TAX — DEDUCTION — CHARITABLE BEQUEST — EXCLUSIVELY — SEC. 812 (d), I. R. C. — A […]
CESSNA v. COMMISSIONER, 2009-301 (T.C. 12-22-2009)
CESSNA v. COMMISSIONER, 2009-301 (T.C. 12-22-2009) WILLIAM RAY CESSNA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,Respondent. No. 30707-08L.United States Tax Court. Filed December 22, 2009. MEMORANDUM OPINION William Ray Cessna, pro se. Jeremy L. McPherson, for respondent. GERBER, Judge: Respondent moved for summary judgment in this section 6320[fn1] collection proceeding involving the filing of a notice […]
PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONS, 30 T.C. 1399 (1958)
PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONS, 30 T.C. 1399 (1958)United States Tax Court. 1958. PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONS. T. C. Memo. Name 1958-138 Walston, Thomas A. 1958-127 Watkins, Dr. W. M., Estate 1958-137 Weinzimer, Sanford H. and Hermine Mosse 1958-158 Weir, Paul V. and Margaret G. 1958-160 Wells, B. Frank, Jr. 1958-77 Western […]
FELMAN v. COMMISSIONER OF INTERNAL REVENUE, 49 T.C. 599 (1968)
FELMAN v. COMMISSIONER OF INTERNAL REVENUE, 49 T.C. 599 (1968) RICHARD L. FELMAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 6107-65.United States Tax Court. Filed March 11, 1968. In 1963 petitioner became entitled to, and received, readjustment pay in the amount of $12,600 under the provisions of the Act of June 28, 1962, Pub.L. […]