§284

Uniband, Inc., Petitioner 140 T.C. No. 13 · 2013

First, unlike a section 17 corporation that is established at the discretion ofthe Secretary ofthe Interior and that is given only the powers that the Secretary ofthe Interior approves, Uniband was established by the decision ofTMBCI and its co-shareholder and was given by them all the lawful powers that a Delaware corporation may possess. Second, unlike a section 17 charter, which "shall not be revoked or surrendered except by Act ofCongress", Uniband exists at the pleasure ofits owner, TMBCI,

Uniband, Inc. v. Commissioner 140 T.C. 230 · 2013

284(a) (2011) (“The Court of Chancery shall have jurisdiction to revoke or forfeit the charter of any corporation for abuse, misuse or nonuse of its corporate powers, privileges or franchises”). Third, Uniband does not possess the special power to purchase restricted Indian lands, a power that a section 17 corporation is given by statute. Four

Suzanne L. Porter a.k.a. Suzanne L. Holman, Petitioners 130 T.C. No. 10 · 2008

284(e), 44 Stat . (Part 2) 67 (overpayments) ; Revenue Act of 1924, ch . 234, sec . 274, 43 Stat . 297 (deficiencies) . - 13 - APA does not limit or repeal our de novo review procedures .' Id. at 53 (Thornton, J ., concurring) . E . Abuse of Discretion and De Novo Revie w We have reviewed the Commissioner's enial of relief in .'° cases arisin

Llwellyn Greene-Thapedi, Petitioner 126 T.C. No. 1 · 2006

284(e), 44 Stat. 67. Thus, in 1924, in Barry, the Board decided it had overpayment jurisdiction, and Congress confirmed the Board's jurisdiction and authority to decide an overpayment in the Revenue Act of 1926. 2. My View My view advances our established precedent that "In view of the statutory scheme as a whole, we think the substantive and

Gwendolyn A. Ewing, Petitioner 122 T.C. No. 2 · 2004

284(e), 44 Stat. 67 (overpayments); Revenue Act of 1924, ch. 234, sec. 274, 43 Stat. 297 (deficiencies). 4 In one of its earliest decisions, the Board of Tax Appeals characterized its scope of review in deficiency proceedings as follows: When a taxpayer brings his case before the Board he proceeds by trial de novo. The record of the case made

Burke v. Commissioner 105 T.C. 41 · 1995

Estate of Baumgardner v. Commissioner 85 T.C. 445 · 1985

Estate of Bailly v. Commissioner 81 T.C. 949 · 1983

Hollie v. Commissioner 73 T.C. 1198 · 1980

Breman v. Commissioner 66 T.C. 61 · 1976

Big Four Industries, Inc. v. Commissioner 40 T.C. 1055 · 1963

Comas, Inc. v. Commissioner 23 T.C. 8 · 1954

Estate of Paul v. Commissioner 16 T.C. 743 · 1951

Cedar Park Assembly of God of Kirkland, Washington v. Myron Kreidler 130 F.4th 757 · Cir.

Owner Operator Independent Drivers Ass'n v. Comerica Bank (In Re Arctic Express Inc.) 636 F.3d 781 · Cir.

Carlton Gunn v. Continental Casualty Company · Cir.

Carlton Gunn v. Continental Casualty Company 968 F.3d 802 · Cir.

Carlton Gunn v. Continental Casualty Company · Cir.

Owner Operator Independent Drivers Ass'n v. Comerica Bank 636 F.3d 781 · Cir.

Estados Unidos Mexicanos v. Smith & Wesson Brands Inc. 91 F.4th 511 · Cir.

20 Citing Cases