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The Tax court had to decide whether the taxpayer had the ability receive the check or whether she faced "substantial limitations" on this ability as a result of the circumstances. The Tax Court noted prior decisions that held a taxpayer to have constructively received funds as of the time of attempted delivery when the taxpayer made a decision ...
United States Tax Court: ... Decided: May 13, 1954 () Citations: T.C. Memo 1954-38; 13 T.C.M. (CCH) 462 (1954) Court membership ... The question for decision was the ...
The Batmans appealed the decision to the Fifth Circuit Court of Appeals. They claimed the Tax Court had given too much weight to their son's infancy, Ray Batman's status as head of the farm and Gerald's being the silent partner. A three-judge panel composed of Joseph Chappell Hutcheson, Jr., Wayne G. Borah and Robert Lee Russell took the case ...
In Jenkins v.Commissioner, T.C. Memo 1983-667 (U.S. Tax Court Memos 1983), [1] the U.S. Tax Court held that the payments Conway Twitty, a country singer, made to investors in a defunct restaurant business known as "Twitty Burger, Inc." were deductible under § 162 of the Internal Revenue Code [2] as ordinary and necessary business expenses of petitioner's business as a country music performer.
Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955), was an important income tax case before the United States Supreme Court.The Court held as follows: Congress, in enacting income taxation statutes that comprehend "gains or profits and income derived from any source whatever," intended to tax all gain except that which was specifically exempted.
Cottage Savings Association v. Commissioner, 499 U.S. 554 (1991), was an income tax case before the Supreme Court of the United States. [1]The Court was asked to determine whether the exchange of different participation interests in home mortgages by a savings and loan association was a "disposition of property" under § 1001(a) of the Internal Revenue Code (since this was the requirement for ...
Carpenter v. Commissioner, T.C. Memo. 1966-228 (1966) was a case decided by the United States Tax Court. [1] Carpenter v. Commissioner addressed the issue of whether a husband and wife could deduct the aggregate fair market value of the wife’s engagement ring from their income tax return, as a casualty loss under §165(a) and (c)(3) of the Internal Revenue Code of 1954, [2] after the husband ...
Justice Thomas wrote the decision of the Court which reversed the Court of Appeals. He wrote that excluded discharged debt is an "item of income", [4] which passes through to shareholders and increases their basis in an S corporation's stock and that pass-through is performed before the reduction of an S corporation's tax attributes.