Category: United States Tax Court Opinions

Docket No. 27187-12. 146 T.C. 39 (2016) MICHAEL JONES AND M. CHASTAIN JONES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. United States Tax Court. Filed February 9, 2016. Counsel: Stephen Edward Silver and Derek W. Kaczmarek, for petitioners. Alicia E. Elliott, for respondent. HOLMES, Judge: Michael Jones is an Arizona judge who claimed deductions on […]

Docket No. 10241-12L. 146 T.C. 17 (2016) LG KENDRICK, LLC, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. United States Tax Court. Filed January 21, 2016. Counsel: Michael E. Lunnon (member), for petitioner. Luke D. Ortner, for respondent. OPINION MARVEL, Judge: Pursuant to section 6330(d)1 petitioner seeks review of determinations by respondent (hereinafter IRS or respondent) […]

Docket No. 2482-14. 146 T.C. 1 (2016) GERD TOPSNIK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. United States Tax Court. Filed January 20, 2016. Counsel: Charles Herbert Magnuson, for petitioner. Michael K. Park and Najah J. Shariff, for respondent. OPINION KERRIGAN, Judge: This case is before the Court on petitioner’s motion for summary judgment and […]

HOSP. CORP. OF AM. SUBS. v. COMMR. OF INTERNAL REVENUE, 107 T.C. 73 (1996) HOSPITAL CORPORATION OF AMERICA AND SUBSIDIARIES, PETITIONERS v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Nos. 10663-91, 13074-91 28588-91, 6351-92.United States Tax Court. Filed September 12, 1996. Ps own, operate, and manage hospitals and related businesses. For taxable year ended 1987, pursuant to sec. […]

OCCIDENTAL LIFE INSURANCE CO. v. COMMR. OF INT. REV., 50 T.C. 726 (1968) OCCIDENTAL LIFE INSURANCE COMPANY OF CALIFORNIA, PETITIONER v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 2630-66.United States Tax Court. Filed August 12, 1968. Petitioner paid over to the estate of a Canadian resident, a former agent of petitioner, renewal commissions becoming due on […]

STEVENS v. COMMISSIONER OF INTERNAL REVENUE, 52 T.C. 330 (1969) BRYAN L. STEVENS AND BRYAN L. STEVENS AS SURVIVING SPOUSE OF ALMA STEVENS,DECEASED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 4719-62.United States Tax Court. Filed May 27, 1969. Petitioner, a noncompetent Indian enrolled with the Gros Ventre Tribe, during the years 1958 and […]

PECKHAM v. COMMISSIONER OF INTERNAL REVENUE, 40 T.C. 315 (1963) HENRY L. PECKHAM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 87720.United States Tax Court. Filed May 15, 1963 Held, amounts expended by a licensed physician as attorney’s fees and related legal expenses in the unsuccessful defense against a prosecution for criminal abortion are not […]

TRAVELERS INS. CO. v. COMMISSIONER OF INTERNAL REVENUE, 6 T.C. 753 (1946) THE TRAVELERS INSURANCE COMPANY, A CORPORATION, PETITIONER, v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket No. 8082.United States Tax Court. Promulgated April 17, 1946. The plea here of estoppel by judgment or res adjudicata is not supported by proof of judgments or decrees rendered in […]

BOYD-RICHARDSON CO. v. COMMISSIONER OF INTERNAL REVENUE, 5 T.C. 695 (1945) BOYD-RICHARDSON COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 2238.United States Tax Court. Promulgated September 11, 1945. EXCESS PROFITS NET INCOME — EXCLUSION FOR RECOVERIES OF BAD DEBTS — RESERVE METHOD. — Petitioner using reserve for bad debts, accompanied by uniform practice of […]

ZAPPO v. COMMISSIONER OF INTERNAL REVENUE, 81 T.C. 77 (1983) ANGELO ZAPPO AND DOROTHY ZAPPO, PETITIONERS v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. No. 6436-78.United States Tax Court. Filed August 3, 1983. Zappo and Murphy formed Company to construct and sell townhouses. New Investors entered the venture by purchasingPage 78 shares of Company and lending money to […]