STEVENS PASS, INC. v. COMMISSIONER OF INTERNAL REVENUE, 48 T.C. 532 (1967) STEVENS PASS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 141-66.United States Tax Court. Filed June 30, 1967. Petitioner purchased 100 percent of the stock of the old company from its shareholders and liquidated the old company pursuant to sec. 332, I.R.C. […]
Category: United States Tax Court Opinions
COLLIS v. COMMISSIONER OF INTERNAL REVENUE, 2010-91 (T.C. 7-12-2010)
COLLIS v. COMMISSIONER OF INTERNAL REVENUE, 2010-91 (T.C. 7-12-2010) RONALD COLLIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,Respondent No. 12663-09S.United States Tax Court. Filed July 12, 2010. [EDITOR’S NOTE: This case is unpublished as indicated by the issuing court.]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 FOR […]
WALL PRODUCTS, INC. v. COMMR. OF INTERNAL REVENUE, 11 T.C. 51 (1948)
WALL PRODUCTS, INC. v. COMMR. OF INTERNAL REVENUE, 11 T.C. 51 (1948) WALL PRODUCTS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 10277.United States Tax Court. Promulgated July 20, 1948. 1. Upon the record, held, that payments made by petitioner to its two principal stockholders during 1942 and 1943 were for the use of […]
HYDRO MOLDING CO., INC. v. COMMR. OF INTERNAL REVENUE, 38 T.C. 312 (1962)
HYDRO MOLDING CO., INC. v. COMMR. OF INTERNAL REVENUE, 38 T.C. 312 (1962) HYDRO MOLDING COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 83975.United States Tax Court. Filed May 28, 1962. Accrual basis corporation is not entitled to a deduction for contribution to a profit-sharing trust fund for the calendar year 1957 where […]
FRUEHAUF v. COMMISSIONER OF INTERNAL REVENUE, 12 T.C. 681 (1949)
FRUEHAUF v. COMMISSIONER OF INTERNAL REVENUE, 12 T.C. 681 (1949) HARVEY C. FRUEHAUF, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 8790.United States Tax Court. Promulgated April 29, 1949. By a trust indenture dated December 30, 1935, petitioner transferred to himself, as trustee, certain shares of the capital stock of the Fruehauf Trailer Co., of […]
TEXSUN SUPPLY CORP. v. COMMR. OF INTERNAL REVENUE, 17 T.C. 433 (1951)
TEXSUN SUPPLY CORP. v. COMMR. OF INTERNAL REVENUE, 17 T.C. 433 (1951) TEXSUN SUPPLY CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 26182.United States Tax Court. Promulgated September 27, 1951. Petitioner and Roseland Manufacturing Company merged on October 31, 1944, under the laws of Louisiana with petitioner as the surviving corporation. In the merger […]
WILKINS v. COMMISSIONER OF INTERNAL REVENUE, 7 T.C. 519 (1946)
WILKINS v. COMMISSIONER OF INTERNAL REVENUE, 7 T.C. 519 (1946) RAYMOND S. WILKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 6569.United States Tax Court. Promulgated August 9, 1946. In the taxable year petitioner was one of the surviving partners of a law partnership. The partnership agreement provided that upon any partner’s decease his estate […]
BERRYMAN v. COMM., INT. REV., T.C. Summary Opinion 2007-138 (T.C. 8-8-2007)
BERRYMAN v. COMM., INT. REV., T.C. Summary Opinion 2007-138 (T.C. 8-8-2007) ROBERT D. AND CAROL A. BERRYMAN, Petitioners v. COMMISSIONER OF INTERNALREVENUE, Respondent. No. 15183-06S.United States Tax Court. Filed August 8, 2007. PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b), THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. Robert D. and Carol […]
MARLOW v. COMMISSIONER, 2010-113 (T.C. 5-20-2010)
MARLOW v. COMMISSIONER, 2010-113 (T.C. 5-20-2010) JAMES E. AND CATHY MARLOW, Petitioners v. COMMISSIONER OF INTERNALREVENUE, Respondent. No. 18721-08L.United States Tax Court. Filed May 20, 2010. MEMORANDUM OPINION Mary Michelle Gillum and Robert B. Nadler, for petitioners. Martha J. Weber, for respondent. DAWSON, Judge: Respondent issued a Notice of Determination Concerning Collection Action(s) Under Section […]
BASILA v. COMMISSIONER OF INTERNAL REVENUE, 36 T.C. 111 (1961)
BASILA v. COMMISSIONER OF INTERNAL REVENUE, 36 T.C. 111 (1961) BASIL F. BASILA AND M. FRANCES BASILA, PETITIONERS, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket No. 61738.United States Tax Court. Filed April 20, 1961. Petitioner Basil F. Basila was president, general manager, and principal shareholder of a company. His employment contract with the company provided for […]