Category: United States Tax Court Opinions

BERETTA v. COMMR. OF INTERNAL REVENUE, 1 T.C. 86 (1942) JOHN K. BERETTA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT.SALLIE WARD BERETTA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket Nos. 107076, 107077.United States Tax Court. Promulgated November 20, 1942. 1. Petitioners were stockholders of a corporation which sold a part of its capital assets for cash […]

LEE ENGINEERING SUPPLY CO. v. COMM’R, 101 T.C. 189 (1993) LEE ENGINEERING SUPPLY CO., INC., PETITIONER v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. No. 19267-90.United States Tax Court. Filed August 30, 1993. In 11385, P, a corporation, decided to terminate its defined benefit pension plan (pension plan). P did not make a contribution required under the minimum […]

HERMETIC SEAL PRODUCTS COMPANY v. RENEGOTIATION BOARD, 41 T.C. 223 (1963) HERMETIC SEAL PRODUCTS COMPANY, P.R., PETITIONER, v. RENEGOTIATION BOARD,RESPONDENT Docket Nos. 961-R, 962-R.United States Tax Court. Filed November 15, 1963. Held, petitioner is not exempt from the provisions of the Renegotiation Act of 1951 merely because it is a Puerto Rican corporation and maintained […]

TECUMSEH COAL CORP. v. COMMR. OF INTERNAL REVENUE, 17 T.C. 636 (1951) TECUMSEH COAL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 30746.United States Tax Court. Promulgated October 10, 1951. By proper notice respondent allowed in part and disallowed in part petitioner’s claim for relief under section 722, I. R. C. In the same […]

WENTWORTH v. COMMISSIONER OF INTERNAL REVENUE, 25 T.C. 1210 (1956) C. H. WENTWORTH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 51260.United States Tax Court. Filed March 12, 1956. A corporation in 1944 credited the accounts receivable account of its controlling stockholder for $180,000, and debited its capital account for the same amount. Earned surplus […]

PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONS, 40 T.C. 1068 (1963)United States Tax Court. 1963. PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONST.C. Memo. Name 1963-245 Western States Investment Corporation 1963-179 Whited, Andrew, Jr., and Frances 1963-179 Whitt, Marvin B. and Edith L. 1963-184 Willey, Harold E. 1963-114 Williams, Walter 1963-132 Williamson, Bernese 1963-188 Wilson, Charlie L. 1963-270 […]

SMITH v. COMMISSIONER OF INTERNAL REVENUE, 66 T.C. 213 (1976) CHARLES G. SMITH AND MARGARET M. SMITH, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 8233-74.United States Tax Court. Filed April 28, 1976. In early 1968 petitioner completed the work which he had undertaken under a subcontract involving the construction of an overpass, and in […]

MITCHELL v. COMMISSIONER, 131 T.C. 215 (2008) LARRY G. AND MARIA A. WALTON MITCHELL, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 2518-04.United States Tax Court. Filed December 15, 2008. P-W received distributions during 2001 made pursuant to a QDRO after her ex-husband retired from the U.S. Air Force. Ps did not include the 2001 […]

BAKER COMMODITIES, INC. v. COMMR. OF INTERNAL REVENUE, 48 T.C. 374 (1967) BAKER COMMODITIES, INC., ET AL.,[fn1] PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket Nos. 1371-65, 5416-65, 5418-65, 5420-65.United States Tax Court. Filed June 23, 1967. [fn1] Cases of the following petitioners are consolidated herewith: Frank Jerome and Helen Jerome, docket No. 5416-65; Varney Jerome […]

SABINE ROYALTY CORP. v. COMMR. OF INTERNAL REVENUE, 17 T.C. 1071 (1951) SABINE ROYALTY CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 25149.United States Tax Court. Promulgated December 29, 1951. 1. INTEREST. — Petitioner, a corporation engaged in the business of investing in oil properties, issued income debentures in exchange for its own stock. […]