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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   owing differences: I --between the amounts of royalties and other expenses referred to in article 74 of the mentioned Law, credited or paid during the base-year, and the minimum percentages established for the respective deduction, according to (b) and (d); II--between the quotas for the purpose of forming depreciation…
2. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
   IRCCourt RulingsMar 25, 2013
   …ner, 178 F.2d 115, 121 (6th Cir. 1949); Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. 1142, 1158 (1980).
3. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
   IRCCourt RulingsDec 20, 2001
   …Ms. Whitehead during the years at issue. See Wichita Terminal Elevator Co. v. Commissioner , 6 T.C. 1158, 1164-1165 (1946), affd. 162 F.2d 513 (10th Cir. 1947). In this connection, we note that in Form 1120 that Burien Nissan
4. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsJan 17, 2024related by meaning
   Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
5. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
   IRCCourt RulingsMay 25, 2005related by meaning
   s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
6. PLR 201040018 — Safe Harbor Limits
   IRCPrivate Letter RulingsOct 8, 2010
   …ttee Report on the Deficit Reduction Act of 1984 (House Report 98 - 861) (the Conference Report) at 1158. Wi th respect to what is meant by “claims incurred”, the Conference Rep ort explains, “Claims are incurred only when an event entitling the employee to benefits, such as a medical expense, a separation, a disabilit…
7. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
   IRCCourt RulingsNov 21, 2023
   …ony would be unfavorable to petitioners . See Wichita Terminal Elevator Co. v. Commissioner, 6 T.C. 1158, 1165 (1946), aff’d , 162 F.2d 513 (10th Cir. 1947) . But where both parties have equal access to the evidence, we do not apply an adverse inference . Jordan v. Commissioner , 134 T.C. 1, 10 (2010), supplemented by …
8. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsFeb 28, 2024related by meaning
   ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
9. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
   IRCTreasury DecisionsAug 28, 2006related by meaning
   INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
10. T.C. Memo. 2001-22 — Robert L. Stahl v. Commissioner
    IRCCourt RulingsJan 31, 2001
    …et the specifications of section 414(p). See Wichita Terminal Elevator Co. v. Commissioner , 6 T.C. 1158, 1165 (1946) (“the failure of a party to introduce evidence within his possession and which, if true, would be favorable to him, gives rise to the presumption that if produced it would be unfavorable”), affd. 162 F.…
11. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    oner , supra at 780. 11 See id. at 773. 12 See Eckel v. Commissioner , T.C. Memo. 1990-174. 13 See, e.g., In re Hatton , 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang , 164 F.3d 1029, 1033 (6th Cir. 1999). section 6653(a), 3 section 6662, 4 section 6013, 5 section 6033, 6 section 6651(f), 7 section 6511, 8 sect…
12. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997
    …le." General Signal Corp. & Subs. v. Commissioner , supra at 232 (quoting H. Conf. Rept. 98-861, at 1158 (1984), 1984-3 C.B. (Vol. 2) 1, 412). In General Signal
13. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998
    …would not have supported their position. See Wichita Terminal Elevator Co. v. Commissioner , 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513 (10th Cir. 1947); see also Simon v. Commissioner , 830 F.2d 499, 506 (3d Cir. 1987), affg. T.C. Memo. 1986156; Schauer v. Commissioner , T.C. Memo. 1987-237; Song v. Commissioner , T…
14. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
15. T.C. Memo. 1998-164 — Roland R. & Virginia A. Fox v. Commissioner
    IRCCourt RulingsMay 5, 1998
    …ers to the children were not shams and that the children had to pay income tax on the rents. Id. at 1158. We are not convinced by petitioners' argument because they have not shown that Oxyfresh would have made payments after Fox died. Mr. Fox's testimony on this point was contradictory. He said that the income stream w…
16. T.C. Memo. 2002-166 — Wayne A. McFadden v. Commissioner
    IRCCourt RulingsJul 2, 2002
    …nt to enforce the collection of the asserted debt. See Estate of Van Anda v. Commissioner , 12 T.C. 1158 (1949), affd. per curiam 192 F.2d 391 (2d Cir. 1951). Some of the factors we consider when determining whether there is a debtor-creditor relationship with a reasonable expectation of repayment are whether: (1) Ther…
17. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
18. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …nforce the collection of the indebtedness. Estate of Van Anda v. - 21 - [*21] Commissioner, 12 T.C. 1158, 1162 (1949), aff'd per curiam, 192 F.2d 391 (2d Cir. 1951). LaShana, Keith, and Freddie Boneparte are petitioner's daughter, son, and brother, respectively. Since they are all petitioner's family members, a transfe…
19. Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in …
    IRCRevenue RulingsDec 28, 2009related by meaning
    ment 2009-88 Announcement 2009-88 A list is provided of organizations now classified as private foundations. Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
20. 55 T.C. 1144 — Loevsky v. Commissioner
    IRCCourt RulingsMar 31, 1971
    …During the period involved herein, L & L had a collective bargaining agreement with Local Union No. 1158 of the International Brotherhood of Electrical Workers, said agreement being effective as of J une 1, 1963. Under the collective bargaining agreement, dated August 12, 1963, L & L recognized the union as the sole an…