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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 ...
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 ...
It seems proper that a substantial amount should [*4] be included in their income for 1948 on account of the winning of the tickets. The problem of arriving at a proper fair figure for this purpose is difficult. The evidence to assist is meager, perhaps unavoidably so. The Court, under such circumstances, must arrive at some figure and has done so.
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.
That left the Tax Court with a decision on whether to defer to circuit court decisions in deciding new cases, knowing that its interpretations might be accepted by some circuit courts and overturned in others. Initially, the Tax Court decided to maintain its own consistency rather than use the circuit court precedents when they differed.
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.
President Calvin Coolidge signing the income tax bill which established the U.S. Board of Tax Appeals; Andrew Mellon is the third figure from the right.. The first incarnation of the Tax Court was the "U.S. Board of Tax Appeals", established by Congress in the Revenue Act of 1924 [4] [5] (also known as the Mellon tax bill) in order to address the increasing complexity of tax-related litigation.
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.