Category: United States Tax Court Opinions

H. J. HEINZ CO. v. COMMISSIONER OF INTERNAL REVENUE, 32 T.C. 22 (1959) H. J. HEINZ COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 44694.United States Tax Court. Filed April 10, 1959. An unused excess profits credit arising in 1941 under section 713 of the Internal Revenue Code of 1939 was not specifically claimed […]

MILBERG v. COMMISSIONER OF INTERNAL REVENUE, 54 T.C. 1562 (1970) JACQUES R. MILBERG AND ELAINE K. MILBERG, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 621-68.United States Tax Court. Filed July 30, 1970 Petitioner transferred a patent to a corporation. The question of whether all substantial rights were transferred was litigated before this Court with […]

WORLD PUBLISHING CO. v. COMMISSIONER OF INTERNAL REVENUE, 35 T.C. 7 (1960) WORLD PUBLISHING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 72034.United States Tax Court. Filed October 7, 1960. Petitioner in 1950 purchased real estate subject to a lease. The lessee had constructed a building on such property in 1928 under a 50-year […]

BOATMAN v. COMMISSIONER OF INTERNAL REVENUE, 32 T.C. 1188 (1959) RALPH A. AND AZALEA BOATMAN, PETITIONERS, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 67388.United States Tax Court. Filed September 14, 1959. Petitioner in 1951 entered into an executory contract for the sale of his farm. The selling price was $60,000 with $12,000 payable upon the […]

CARDINAL CORPORATION v. COMMR. OF INTERNAL REVENUE, 52 T.C. 119 (1969) CARDINAL CORPORATION, LOUISVILLE, KENTUCKY (FORMERLY: CARDINAL LIFEINSURANCE CO.), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 4778-64.United States Tax Court. Filed April 21, 1969. 1. Held, an amount received by petitioner in 1958 was not includable in gross income. Such amount was received […]

BROWNE v. COMMISSIONER OF INTERNAL REVENUE, 73 T.C. 723 (1980) ALICE PAULINE BROWNE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 4466-77.United States Tax Court. Filed January 22, 1980. Held: 1. Costs of obtaining a bachelor’s degree in accounting not deductible because the expenses were incurred to meet the minimum educational requirement for qualification in […]

GALLADE v. COMMISSIONER OF INTERNAL REVENUE, 106 T.C. 355 (1996) ALFRED E. GALLADE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Nos. 791-94, 792-94.United States Tax Court. Filed May 28, 1996. C, P’s wholly owned corporation, operated a pension plan in which P participated. Because of C’s poor financial disposition, P executed a “waiver”, to assign his […]

LANG v. COMMISSIONER OF INTERNAL REVENUE, 41 T.C. 352 (1963) JOHN C. AND MARY LANG, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 1708-62.United States Tax Court. Filed December 9, 1963. Held, salary received by taxpayer from his employer during his absence from work because of illness is not excludable from his gross income as […]

EHRET-DAY CO. v. COMMISSIONER OF INTERNAL REVENUE, 2 T.C. 25 (1943) EHRET-DAY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 109528.United States Tax Court. Promulgated June 8, 1943. 1. During the taxable year the petitioner performed the work of constructing a building in all important particulars called for by the contract, but at the […]

MORGAN v. COMMISSIONER OF INTERNAL REVENUE, 42 T.C. 1080 (1964) ELISE McK. MORGAN, ET AL.,[fn1] PETITIONERS, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket Nos. 1793-62, 1794-62, 3038-62.United States Tax Court. Filed September 21, 1964. [fn1] Proceedings of the following petitioners are consolidated herewith: Edwin Morgan, docket No. 1794-62; and Edwin and Elise McK. Morgan, docket No. […]