- Alexandria Amusement Co., 16 T.C. 446 (1951) Petitioner not entitled to relief under Section 722 of the IRC of 1939.
- American Pitch Pine Export Co., Inc., 8 T.C.M. (CCH) 976(1949) Reasonable compensation of key management executives determined.
- Andalex Resources, Inc., et al. v. United States, 311 F.3d 623 (Fed. Cl.) (2002) Coal producers not entitled to prejudgment interest under 28 USC 2411 on judgment that awarded them a refund of excise taxes held unconstitutional under the Export Clause
- Anders v. Commissioner, 68 T.C. 474 (1977) Sale of option not a sham.
- United States v. James A. Baker, Crim. Action No. 85-00087(B) (W.D. Va. tried Mar. 11-13, 1986) Taxpayer acquitted of tax evasion by Jury.
- Beecham, Inc. v. United States, 32 A.F.T.R.2d 73-5916 (E.D. Tenn.) (1973) Payments were advanced costs, not rental income.
- Belcher v. United States, 6 A.F.T.R.2d 5495 (W.D. Va.) (1960) Corporate officer not liable for failure to collect and pay over withheld taxes.
- Arthur N. Blum, 11 T.C. 101 (1948) Payments determined as compensation for personal services and not for sale of patent.
- B.B. Carter v. United States, No. 457 (S.Ct. filed Oct. 10, 1955) United States Supreme Court remanded case to District Court after Government conceded error in taxpayer
conviction for tax evasion.
- Clark v. United States, 200 F.Supp. 668 (E.D. Tenn.) (1961) Capital gain treatment granted taxpayers on sale of subdivided lots.
- Norman E. Clifton, 17 T.C.M. (CCH) 316 (1958) Coal miner entitled to percentage depletion.
- Cobb v. Commissioner, 173 F.2d 711 (6th Cir.) (1949) Payments not deductible under section 23(a)(2) of IRC of 1939 [now section 212].
- Conestoga Transportation Co., 17 T.C. 506 (1951) No income realized. Petitioner's assets determined to be less than its liabilities both before and after it purchased its
obligations at less than face value.
- Consolidation Coal Company, et al. v. United States, 54 Fed. Cl. 14 (2002) Court did not have jurisdiction to consider constitutional claim by coal exporters for refund of the
reclamation fee imposed on exported coal.
- Consolidation Coal Company v. United States, 94 A.F.T.R.2d 2004-5556 (Fed. Cir.) (2003) Court of Federal Claims has jurisdiction to consider constitutional claim for refund
of reclamation fees. Court of Federal Claims reversed.
- Raymond E. Cooper, 39 T.C. 253 (1962) Coal miner not entitled to percentage depletion.
- Cooper v. United States, 330 F.2d 163 (4th Cir.) (1964) Coal miner entitled to percentage depletion. Tax Court reversed.
- Estate of George L. Cury, 23 T.C. 305 (1954) Income and transferee liability determined and fraud penalty determined against one taxpayer.
- United States v. Sol W. Cury, 7 A.F.T.R.2d 1759 (W.D. Va.) (1961) Government's refusal to grant an extension was an arbitrary and capricious abuse of discretion; lower
interest rate applied.
- Danville Plywood Corp. v. United States, 899 F.2d 3 (Fed. Cir.) (1990) Entertainment expense not allowed.
- Dotson v. United States, 173 Ct. Cl. 541 (1965) Coal miners not entitled to percentage depletion.
- Dillow v. United States, 2 A.F.T.R.2d 6533 (W.D. Va.) (1958) Officers not liable for unpaid corporate admission taxes.
- Dobyns-Taylor Hardware v. United States, 278 F.Supp. 538 (E.D. Tenn.) (1967) Bad debt deduction disallowed; theft loss deduction allowed.
- Dominion National Bank v. United States, 87 F.Supp. 709 (M.D. Tenn.) (1950) Document created four distinct trusts and income should be taxed to four rather than one trust.
- Marion J. Epley, Jr., 13 T.C. 77 (1949) Wife's share of community income not excluded from taxable income by Section 6(d)(1) of IRC of 1939.
- Fairmount Park Raceway, Inc. v. Commissioner, 327 F.2d 780 (7th Cir.) (1964) Amounts received from purported sale were rentals from sublease of property.
- First Federal Savings and Loan Association of Bristol v. United States, 660 F.2d 767 (Ct. Cl.) (1981) Regulation section 1.595-1, which would treat rentals from foreclosed
property as current taxable income, struck down as contrary to statute's plain language.
- Gardens of Faith, 23 T.C.M. (CCH) 1045 (1964) Payments received were taxable as dividends and not allowed as deductions to corporation.
- Gardens of Faith v. Commissioner, 345 F.2d 180 (4th Cir.) (1965) Payments received were taxable as dividends and not allowed as deduction to corporation. Tax Court
decision affirmed.
- Green-Haldeman v. Commissioner, 282 F.2d 884 (9th Cir.) (1960) Rental cars held primarily for sale. Capital gain treatment denied taxpayer.
- Guynn v. United States, 309 F.Supp. 233 (W.D. Va.) (1970) Residence not included in gross estate.
- United States v. Guynn, 437 F.2d 1148 (4th Cir.) (1971) Residence included in gross estate. Lower court reversed.
- Ed Haren, 20 T.C.M. (CCH) 432 (1961) Fraud penalty not imposed.
- Harvey v. United States, 234 F.Supp. 887 (W.D. Va.) (1964) Purchase price of stock subject to admission tax.
- Raymond M. Hessert, 6 T.C.M. (CCH) 1190 (1947) Payments determined as for sale of patent and not for personal services.
- Gifford Hill & Co., 11 T.C. 802 (1948) Regulation determined to be an incorrect interpretation of "mineral property" as defined in Section 735(a)(6) of IRC of 1939; Taxpayers
treatment of excluded profits sustained.
- Cecil R. Hopkins, 30 T.C. 1015 (1958) Tax Court disallowed deduction for litigation expenses.
- Cecil R. Hopkins v. Commissioner, 271 F.2d 166 (6th Cir.) (1959) Appellate Court reversed Tax Court and allowed litigation expenses as a deduction.
- Huff-Cook Mutual Burial Association v. United States, 327 F.Supp. 1209 (W.D. Va.) (1971) Reserves claimed by taxpayer sustained.
- E. Ward King v. Commissioner, 55 T.C. 677 (1971) Distribution of dividend requirements of IRC Section 355 not met; distributions are taxable.
- King, et al. v. Commissioner, 458 F.2d 245 (6th Cir.) (1972) Distributions not taxable under IRC Section 355. Tax Court reversed.
- Lambert, et al. v. United States, 56 A.F.T.R.2d 85-6575 (W.D. Va.) (1985) Taxpayer estate value predominantly sustained.
- Latimer-Looney Chevrolet, 19 T.C. 120 (1952) "Demonstrators" and other cars were held primarily for use in taxpayer's trade or business and upon sale were entitled to
capital gain treatment.
- Cecil C. Lawson, 22 T.C.M. (CCH) 851 (1963) Coal miner denied percentage depletion.
- Lawson v. Commissioner, 350 F.2d 396 (4th Cir.) (1965) Coal miner not entitled to percentage depletion. Tax Court decision affirmed.
- Leonard W. Lea, 16 T.C.M. (CCH) 144 (1957) Fraud penalty rejected.
- Leonard W. Lea, 16 T.C.M. (CCH) 490 (1957) Fraud penalty rejected.
- Lester Lumber Co., 14 T.C. 255 (1950) Distribution of surplus determined to be taxable dividend.
- Lipman Estate v. United States, 245 F.Supp. 393 (E.D. Tenn.) (1965) Installment sale treatment allowed taxpayer.
- United States v. Lipman Estate, 376 F.2d 455 (6th Cir.) (1967) Installment sale treatment allowed taxpayer. Lower court affirmed.
- Joseph Lupowitz Sons, et al., 31 T.C.M. (CCH) 1169 (1972) Taxpayer determined to be a personal holding company because of accrued interest income.
- Joseph Lupowitz Sons, Inc. v. Commissioner, 497 F.2d 862 (3rd Cir.) (1974) Amounts advanced to corporation determined to be capital contributions, not loans. No
interest income. No personal holding company. Tax Court reversed.
- Mason & Dixon Lines, Inc. v. United States, 629 F.2d 572 (E.D. Tenn.) (1981) Liquidated damages imposed for overweight trucks not a deductible business expense.
- Mason & Dixon Lines, Inc. v. United States, 708 F.2d 1043 (6th Cir.) (1983) Deduction allowed for liquidated damages imposed on trucking company under Virginia law for
operating overweight vehicles. Lower court reversed.
- Walter Bernard McCall, 27 T.C. 133 (1956) Coal mine operator entitled to percentage depletion.
- Walter Bernard McCall, 37 T.C. 674 (1962) Coal mine operator not entitled to percentage depletion.
- McCall v. Commissioner, 312 F.2d 699 (4th Cir.) (1963) Coal mine operator not entitled to percentage depletion.
- Herbert J. McClelland, 83 T.C. 958 (1984) Certain activities determined not to be coal mining processes for purpose of the percentage depletion.
- Gordon M. McIntyre, 17 T.C.M. (CCH) 764 (1958) Taxpayer liable for penalties for failure to file estimated tax and for substantial underestimation of tax.
- Gordon M. McIntyre v. Commissioner, 272 F.2d 188 (6th Cir.) (1959) Taxpayer not liable for failure to file estimated tax and substantial underestimation of tax. Tax Court
reversed.
- Meadows v. United States, 6 A.F.T.R.2d 5369 (W.D. Va.) (1960) Coal miner not entitled to depletion.
- Robert Lee Merritt, 39 T.C. 257 (1962) Coal miner not entitled to percentage depletion.
- Merritt v. Commissioner, 330 F.2d 161 (4th Cir.) (1964) Coal miner entitled to percentage depletion. Tax Court reversed.
- Commissioner v. Merritt, 85 S.Ct. 1207 (1965) Coal miner not entitled to percentage depletion. Circuit Court reversed.
- Moose Coal Co., Inc., 69 A.F.T.R.2d 92-1485 (W.D. Va.) (1991) Taxpayer entitled to refund. Excise tax improperly imposed on raw coal tonnage.
- Old Dominion Plywood Corp., 25 T.C.M. (CCH) 678 (1966) Bad debt deduction disallowed corporation; ordinary loss allowed stockholders.
- Rowe, et al. v. United States, 655 F.2d 1065 (Ct. Cl.) (1981) Cost of transporting coal to independent processing facility not included in gross income from mining for coal
depletion purposes.
- HR Smith, 10 T.C. 398 (1948) Long Term Capital Gain allowed on sale of partnership interest.
- Stallard v. United States, 170 F.Supp. 267 (W.D. Va.) (1958) Coal miner entitled to depletion.
- Stendig v. United States, 651 F.Supp. 1193 (W.D. Va.) (1987) Amounts deposited in replacement and operating reserves includable in income.
- Stendig v. United States, 843 F.2d 163 (4th Cir.) (1988) Amounts deposited in replacement and operating reserves includable in income. Lower court affirmed.
- Stilwell v. United States, 152 F.Supp. 111 (W.D. Va.) (1957) Taxpayer not entitled to depletion.
- Stilwell v. United States, 250 F.2d 736 (4th Cir.) (1957) Taxpayer entitled to depletion. District Court reversed.
- Irene Nunnery Theriot, 15 T.C. 912 (1951) Taxpayer not permitted to change to a fiscal year basis.
- Tri-City Advertising, Inc., 54 T.C.M. (CCH) 1537 (1988) Corporation did not accumulate income beyond reasonable business needs.
- Winters Coal Company v. Commissioner, 57 T.C. 249 (1971) Taxpayer not entitled to depletion.
- Winters Coal Co., Inc. v. Commissioner, 496 F.2d 995 (5th Cir.) (1974) Taxpayer entitled to percentage depletion. Tax Court reversed.
|
|