RAY ET AL., DOING BUSINESS AS SUPERIOR UNIFORM CAP & SHIRT MFG. CO.,

v.

BOWLES, PRICE ADMINISTRATOR

Citator

Cited By

• Commissioner of Internal Revenue v. McCoy, 484 U.S. 3 (U.S. 1987)
  …ssue that was not the subject of the Tax Court proceeding or to grant relief that is beyond the powers of the Tax Court itself. Taylor v. Commissioner, 258 F. 2d 89, 91 (CA2 1958); Vandenberge v. Commissioner, 147 F. 2d 167, 168 (CA5), cert. denied, 325 U. S. 875 (1945). See Commissioner v. Gooch Milling & Elevator Co., 320 U. S. 418 (1943). But cf. Hormel v. Helvering, 312 U. S. 552 (1941); Singleton v. Wulff, 428 U. S. 106, 120-121 (1976). The Court of Appeals in this case clearly exceeded its jurisdi…
• Cont'l Equities, Inc. v. Commissioner OF Internal Revenue, 551 F.2d 74 (5th Cir. 1977)
  …2, 64 S.Ct. 184, 186, 88 L.Ed. 139, 143 (1943); Rothensies v. Electric Storage Battery Co., 329 U.S. 296, 303, 67 S.Ct. 271, 274, 91 L.Ed. 296, 301 (1946); Vandenberge v. Commissioner of Internal Revenue, 147 F. 2d 167, 168 (5th Cir.), cert. denied, 325 U.S. 875, 65 S.Ct. 1556, 89 L.Ed. 1993 (1945).9 Continental contends that Subtitle D of the Act (Sec [*83] tions 951-962) changed this settled rule by granting the Tax Court jurisdiction over equitable claims. Since we disagree, we do not reach the question…
• Taylor v. Commissioner OF Internal Revenue, 258 F.2d 89 (2d Cir. 1958)
  …2, certiorari denied 348 U.S. 936, 75 S.Ct. 355, 99 L.Ed. 733. Nor is this Court empowered to take any action prohibited to the Tax Court. Our function is one of review. See Vandenberge v. Commissioner, 5 Cir., 1945, 147 F. 2d 167, certiorari denied 325 U.S. 875, 65 S.Ct. 1556, 89 L.Ed. 1993. It is suggested, however, that the Tax Court has jurisdiction to determine the net deficiency for the year and that the taxes paid by the Newcombes are in effect a tax paid by petitioner which reduces the net deficien…