Category: United States Tax Court Opinions

BJR CORPORATION v. COMMISSIONER OF INTERNAL REVENUE, 67 T.C. 111 (1976) BJR CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 3358-75.United States Tax Court. Filed November 2, 1976. 1. Held, since petitioner failed to prove that the taxpayer’s return for the taxable period ending May 31, 1970, was filed more than 3 years prior […]

CHARLESTON NATIONAL BANK v. COMMR. OF INTERNAL REVENUE, 20 T.C. 253 (1953) THE CHARLESTON NATIONAL BANK, CHARLESTON, WEST VIRGINIA, A NATIONALBANKING ASSOCIATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 33231.United States Tax Court. Promulgated April 30, 1953. 1. For the taxable years 1944 and 1945, petitioner paid premiums on life insurance policies held as […]

CAMPBELL v. COMMISSIONER OF INTERNAL REVENUE, 15 T.C. 312 (1950) ROBERT CAMPBELL, PETITIONER, ET AL.,[fn1] v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket Nos. 15998, 15999, 16000, 16001, 16002, 16003, 21392, 21393, 21394,21395, 21396, 21397.United States Tax Court. Promulgated September 28, 1950. [fn1] Proceedings of the following petitioners are consolidated herewith: Andrew H. Campbell; Joseph E. Campbell: […]

DuGRENIER INC. v. COMMISSIONER OF INTERNAL REVENUE, 58 T.C. 931 (1972) ARTHUR H. DuGRENIER, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 502-70.United States Tax Court. Filed August 29, 1972. Petitioner made payment to the estate of a former shareholder in settlement of a cause of action wherein the estate asserted that it received […]

ESTATE OF ELLIS v. COMMR. OF INTERNAL REVENUE, 26 T.C. 694 (1956) ESTATE OF HARRY A. ELLIS, DECEASED, HELEN R. ELLIS, BERNARD B. LARGMAN ANDDAN DENENBERG, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 55204.United States Tax Court. Filed June 26, 1956. ESTATE TAX — MARITAL DEDUCTION — TRUST WITH INCOME FOR LIFE TO […]

McCABE v. COMMISSIONER OF INTERNAL REVENUE, 76 T.C. 876 (1981) DENNIS McCABE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. No. 1536-78.United States Tax Court. Filed June 3, 1981. T, a New York City police officer, is required to carry his revolver at all times while in New York City. T lives in a relatively remote […]

ERNEST W. BROWN, INC. v. COMMR. OF INTERNAL REVENUE, 28 T.C. 682 (1957) ERNEST W. BROWN, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 58017.United States Tax Court. Filed June 21, 1957. 1. DEDUCTION — LOSS — TERMINATION OF CONTRACTS AND BUSINESS. — The taxpayer has not shown its right to deduct in 1952 […]

FUNKHOUSER v. COMMISSIONER OF INTERNAL REVENUE, 44 T.C. 178 (1965) E. N. FUNKHOUSER, AND ESTATE OF NELLIE S. FUNKHOUSER, DECEASED, E. N.FUNKHOUSER, EXECUTOR, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 2808-63.United States Tax Court. Filed May 13, 1965. Entire business enterprise of existing consolidated corporation was transferred to a new corporation which took over […]

ESTATE OF BISCHOFF v. COMMISSIONER, 69 T.C. 32 (1977) ESTATE OF BRUNO BISCHOFF, DECEASED, HERBERT BISCHOFF AND ALVINA L. MARTIN,EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENTESTATE OF BERTHA BISCHOFF, DECEASED, HERBERT BISCHOFF AND ALVINA L.MARTIN, EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket Nos. 312-72, 1035-73.United States Tax Court. Filed October 20, 1977. Within […]

BIRCH RANCH OIL CO v. COMMR. OF INTERNAL REVENUE, 13 T.C. 930 (1949) BIRCH RANCH OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 8720.United States Tax Court. Promulgated December 15, 1949. The petitioner corporation, which kept its books on the cash basis, owned substantially all land comprised in a California reclamation district. The […]