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 […]
Category: United States Tax Court Opinions
ACME BREWERIES v. COMMISSIONER OF INTERNAL REVENUE, 15 T.C. 682 (1950)
ACME BREWERIES v. COMMISSIONER OF INTERNAL REVENUE, 15 T.C. 682 (1950) ACME BREWERIES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 11156.United States Tax Court. Promulgated November 24, 1950. Norman A. Eisner, Esq., for the petitioner. C. A. Ray, Esq., and William J. Stetter, Esq., for the respondent. SUPPLEMENTAL OPINION. TIETJENS, Judge: The necessity for […]
NORTH AMERICAN SERVICE CO. v. COMMR. OF INTERNAL REV., 33 T.C. 677 (1960)
NORTH AMERICAN SERVICE CO. v. COMMR. OF INTERNAL REV., 33 T.C. 677 (1960) NORTH AMERICAN SERVICE CO., INC., PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT.NORTH AMERICAN SERVICE CO., INC., NORTH AMERICAN SERVICE COMPANY ANDHIGHWAY ADVERTISING COMPANY OF NEW YORK, INC., PETITIONERS, v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket Nos. 61968, 61969.United States Tax Court. Filed January 18, […]
DOVER CORPORATION v. COMMISSIONER, 122 T.C. 324 (2004)
DOVER CORPORATION v. COMMISSIONER, 122 T.C. 324 (2004) DOVER CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNALREVENUE, Respondent. No. 12821-00.United States Tax Court. Filed May 5, 2004. D and H, United Kingdom corporations, were controlled foreign corporations with respect to P. H was a wholly owned subsidiary of D. In 1997, D sold the stock […]
BENZIN v. COMMISSIONER OF INTERNAL REVENUE, 2009-198 (T.C. 12-28-2009)
BENZIN v. COMMISSIONER OF INTERNAL REVENUE, 2009-198 (T.C. 12-28-2009) DONALD A. BENZIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,Respondent No. 7811-09S.United States Tax Court. Filed December 28, 2009. [EDITOR’S NOTE: This case is unpublished as indicated by the issuing court.] SUMMARY OPINION PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b), THIS OPINIONMAY NOT BE TREATED AS PRECEDENT […]
KINGBAY v. COMMISSIONER OF INTERNAL REVENUE, 46 T.C. 147 (1966)
KINGBAY v. COMMISSIONER OF INTERNAL REVENUE, 46 T.C. 147 (1966) CURTIS W. KINGBAY AND LAURA M. KINGBAY, PETITIONERS, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 469-64.United States Tax Court. Filed April 29, 1966. Held: Deduction of partnership loss by limited partners is allowed only to the extent of the adjusted bases of their interests in […]
ESTATE OF WEIN v. COMMR. OF INTERNAL REVENUE, 40 T.C. 454 (1963)
ESTATE OF WEIN v. COMMR. OF INTERNAL REVENUE, 40 T.C. 454 (1963) ESTATE OF DAVID WEIN, DECEASED, AND ESTATE OF EDITH WEIN, DECEASED, SIDNEYWEIN, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 91499.United States Tax Court. Filed May 31, 1963. Decedent David Wein, a sole proprietor of a business, elected to have said business […]
TRINITY IND. v. COMM., OF I. R. S., 132 T.C. No. 2 (T.C. 1-28-2009)
TRINITY IND. v. COMM., OF I. R. S., 132 T.C. No. 2 (T.C. 1-28-2009) TRINITY INDUSTRIES, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OFINTERNAL REVENUE, Respondent. No. 12395-06.United States Tax Court. Filed January 28, 2009.Page 1 Company T, a member of P’s affiliated group, contracted to build barges for two established customers; pursuant to an interim […]
HOPTOWIT v. COMMISSIONER OF INTERNAL REVENUE, 78 T.C. 137 (1982)
HOPTOWIT v. COMMISSIONER OF INTERNAL REVENUE, 78 T.C. 137 (1982) WILLIAM HOPTOWIT AND ELAINE A. HOPTOWIT, ET AL.,[fn1] PETITIONERS v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Nos. 7095-79, 7096-79, 7097-79.United States Tax Court. Filed January 28, 1982. [fn1] Cases of the following petitioners are consolidated herewith: Elaine A. Hoptowit, docket No. 7096-79, and William H. Hoptowit, docket […]
ANASTASIO v. COMMISSIONER OF INTERNAL REVENUE, 67 T.C. 814 (1977)
ANASTASIO v. COMMISSIONER OF INTERNAL REVENUE, 67 T.C. 814 (1977) JOSEPH ANASTASIO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 7134-74.United States Tax Court. Filed February 16, 1977. In 1970, petitioner won $100,000 in a lottery. Because petitioner was a minor at that time, under the applicable State law, the prize money was paid in […]