Category: United States Tax Court Opinions

SEVERO v. COMMISSIONER, 129 T.C. 160 (2007) MICHAEL V. SEVERO AND GEORGINA C. SEVERO, PETITIONERS v. COMMISSIONEROF INTERNAL REVENUE, RESPONDENT. Docket No. 6346-06L.United States Tax Court. Filed November 15, 2007. With the late filing of their 1990 joint Federal income tax return, petitioners failed to pay most of the $63,499 tax reported due. In 1994, […]

BROWN v. COMMISSIONER OF INTERNAL REVENUE, 85 T.C. 397 (1985) DENNIS S. BROWN, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Nos. 29929-82, 2313-83, 3083-83, 3503-83.United States Tax Court. Filed December 18, 1985. On October 24, 1985, by order of Judge Perry Shields the opinion filed in this case on August 26, 1985, was withdrawn. […]

BOT v. COMMISSIONER OF INTERNAL REVENUE, 118 T.C. 138 (2002) RICHARD J. BOT AND PHYLLIS BOT, Petitioners v. COMMISSIONER OF INTERNALREVENUE, Respondent No. 14155-98.United States Tax Court. Filed February 15, 2002. Ps maintained active memberships in an agricultural cooperative, which processed and sold corn produced by its members. As active members, Ps were obligated to […]

HUDDLESTON v. COMMISSIONER OF INTERNAL REVENUE, 100 T.C. 17 (1993) ALICIA ST. JOHN HUDDLESTON, TRANSFEREE, A MINOR, ET AL.,[fn1] PETITIONERS v.COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Nos. 14693-90, 17507-90, 17536-90, 17547-90, 20536-90.United States Tax Court. Filed January 13, 1993. [fn1] Cases of the following petitioners are consolidated herewith: Kevin D. Huddleston, Transferee, docket No. 17507-90; Lindsay […]

MONROE v. COMMISSIONER OF INTERNAL REVENUE, 7 T.C. 278 (1946) M. M. MONROE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket No. 6380.United States Tax Court. Promulgated June 28, 1946. Petitioner and his son executed an agreement of partnership under which his minor son agreed to devote his entire time to the business. The son, […]

SOUTH TACOMA MOTOR CO. v. COMMR. OF INTERNAL REVENUE, 3 T.C. 411 (1944) SOUTH TACOMA MOTOR COMPANY, A CORPORATION, PETITIONER, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT. Docket No. 110784.United States Tax Court. Promulgated March 6, 1944. Petitioner sold, for cash, coupon books entitling the purchaser to certain services, which might be called for and performed after […]

KNAPP v. COMMISSIONER OF INTERNAL REVENUE, 23 T.C. 716 (1955) BESSIE KNAPP, ET AL.,[fn1] PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket Nos. 44348, 44351-44354, 44407-44411.United States Tax Court. Filed January 26, 1955. [fn1] Proceedings of the following petitioners are consolidated herein: Frederick M. Knapp, Docket No. 44351; Gilson Knapp, Docket No. 44352; F. E. Knapp, […]

ESTATE OF NOCK v. COMMISSIONER OF INTERNAL REVENUE, 49 T.C. 263 (1967) ESTATE OF PAULINE E. NOCK, DECEASED, BARBARA ANN LYTLE, ADMINISTRATRIX,WITH WILL ANNEXED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket No. 7258-65.United States Tax Court. Filed December 26, 1967. Pauline E. Nock was bequeathed a restricted stock option by her late husband. He had […]

ESTATE OF NITTO v. COMMISSIONER OF INTERNAL REVENUE, 13 T.C. 858 (1949) ESTATE OF JOSEPH NITTO, A MINOR, ANNETTE CARAVETTA NITTO, GUARDIAN,PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.ESTATE OF FRANK NITTO, DECEASED, ANNETTE CARAVETTA NITTO, ADMINISTRATRIX,PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.ANNETTE CARAVETTA NITTO, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket Nos. 8840, 8841, 8842.United […]

COLONIAL SAVINGS ASS’N. v. COMMR. OF INTERNAL REVENUE, 85 T.C. 855 (1985) COLONIAL SAVINGS ASSOCIATION AND SUBSIDIARIES, PETITIONERS v. COMMISSIONEROF INTERNAL REVENUE, RESPONDENT. No. 25477-82.United States Tax Court. Filed November 26, 1985. P, a savings and loan association, was entitled to receive penalties from depositors because of premature withdrawals from their accounts. P generally credited […]