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94 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008
    …h v. Allwright , 321 U.S. 649, 669 (1944) (Roberts, J. dissenting). 5 See Ballard v. Commissioner , 544 U.S. 40, 63 (2005) (“To
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  3. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
  4. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …) 811 $152,127 Review & Update Notice (Subsequent Years) 406 76,064 Mail Disclosure (Annually) $381,544 First Year Total 811 152,127 381,544 Subsequent Year Total 406 76,064 381,544 Three-Year Average Total 541 101,418 381,544 Overall Summary The paperwork burden associated with the proposed rule is presented in Table …
  5. 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…
  6. T.C. Memo. 2008-249 — David A. Hughes v. Commissioner
    IRCCourt RulingsNov 3, 2008
    …thereof, if there is an evidentiary basis for doing so . Cohan v . Commissioner , 39 F .2d 540, 543-544 (2d Cir . 1930) ; Vanicek v . Commissioner , 85 T .C . 731, 742-743, (1985) ., In thos e instances , the Court may_est mate heavily if appropriate again t the he allowable expense, bearing taxpayer 1whose inexactitud…
  7. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    the estimate. See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). In estimating the amount allowable, we bear heavily against the taxpayer whose inexactitude is of his own making. See Cohan v. Commissioner, 39 F.2d at 544. Section 274(d) imposes strict …
  8. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987
    …spatch of business. U.S. Const. art. III, sec. 1; Opinion of the Comptroller General, 44 Comp. Gen. 544 (1965). U.S. Const. art. III, sec. 1; Opinion of the Comptroller General, 44 Comp. Gen. 544 (1965).
  9. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998★ strong match
    …with their plain meaning. United States v. American Trucking Associations, Inc. , 310 U.S. 534, 543-544 (1940); Campbell v. Commissioner , supra at 62. We find that we must
  10. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    lure to report any portion of the distributions. Thus, we find petitioner liable for the negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock. In keeping with the above holdings, Decision will be entered under Rule 155 .
  11. 80 FR 72192 — Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protec…
    IRCFinal Rules (FR)Nov 18, 2015
    … Grandfathered Plans Change in Carrier Disclosure (§ 147.140(a)(3)(i)) 0938-1093 7,440 7,440 248 $7,544 $0 $7,544
  12. 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’ …
  13. 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…
  14. T.C. Memo. 2009-133 — Paul Rudnick v. Commissioner
    IRCCourt RulingsJun 9, 2009
    …lowable in som e .circumstances (the Cohan rule) . See Cohan v . Commissioner , 39 F .2dij-540, 543-544 (2diCir . 1930) . There must be sufficient evidence in .,the record, however, to permit us to conclude that the taxpayer paid or incurred a deductible expense in at leas t .the amount allowed . See Williams v . Unite…
  15. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…
  16. 37 T.C. 7 — Barbourville Brick Co. v. Commissioner
    IRCCourt RulingsOct 9, 1961related by meaning
    ring v. Wood, 309 U.S. 344 (1940). But no such action was taken, and it is most unlikely that respondent’s position was in fact unknown to petitioner. Giving petitioner the benefit of all doubts, however, and assuming, contrary to the fact, that respondent’s position at the trial was a departure from the theory of the …
  17. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …lliams v. United States, 245 F.2d 559, 560 (5th Cir. 1957); Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). But see sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). In these instances, the Court is permitted to approximate…
  18. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  19. T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b…
    IRCTreasury DecisionsDec 7, 2015
    … Grandfathered Plans Change in Carrier Disclosure (§ 147.140(a)(3)(i)) 0938–1093 7,440 7,440 248 $7,544 $0 $7,544
  20. 50 T.C. 583 — Audrey Realty, Inc. v. Commissioner
    IRCCourt RulingsJul 18, 1968
    …ces rendered by shareholders (including members of the shareholder’s family as described in section 544(a) (2)), * * *. [Emphasis supplied.] That this amendment expressly limits business deductions for the purpose at hand to those only allowable under section 162 or section 404 is strongly borne out by legislative hist…