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1. 78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
   IRCFinal Rules (FR)Sep 19, 2013
   T [Removed] Par. 17. Section 1.168(i)-7T is removed. Par. 18. Section 1.263(a)-0 is amended by: 1. The table of contents introductory text is revised. 2. Revising the section heading and entries to the table of contents for §§ 1.263(a)-1, 1.263(a)-2 and 1.263(a)-3. 3. Adding § 1.263(a)-6 to the table of contents. The r…
2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
3. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
   IRCFinal Rules (FR)Oct 7, 2021
   …he DOL and the Department of the Treasury, the DOL's share is 3,241 hours at an equivalent cost of $263,706 annually. The DOL's share of the cost burden is $1,627,679 annually. The summary of burden for DOL and the Department of the Treasury's information collection has also been provided below. Table 60—DOL and Depart…
4. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
   IRCCourt RulingsJun 18, 1999related by meaning
   1 Unless otherwise indicated, all section references are to (continued...) T.C. Memo. 1999-199 UNITED STATES TAX COURT DON LAVERNE CLARKE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 151-97. Filed June 18, 1999. Don Laverne Clarke, pro se. Anthony Hoefer , for respondent. MEMORANDUM FINDINGS …
5. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
   IRCCourt RulingsJan 28, 2014★ strong match
   her authority that would distinguish the Martin cases from the issue presented before the Court. Accordingly, petitioners have not met their burden of proving that the weight of the authorities supporting the treatment of the IRA - 25 - [*25] distributions is substantial in relation to the weight of the authorities sup…
6. 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…
7. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
   IRCCourt RulingsNov 7, 1996related by meaning
   T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
8. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
   IRCCourt RulingsOct 3, 1989related by meaning
   e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
9. T.C. Memo. 2003-32 — Howard E. Clendenen v. Commissioner
   IRCCourt RulingsFeb 12, 2003related by meaning
   (hereinafter the CONTROLLING CASE). 3. All issues involving the above adjustments shall be resolved as if the petitioner in this case were the same as the taxpayer in the CONTROLLING CASE. Both stipulations to be bound also provided: 4. A decision shall be submitted in this case when the decision in the CONTROLLING CAS…
10. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    s, earnings, and reasonable charges) pursuant tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not : rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant to Rev. Proc . 2005-25, lsupra. Held, further, P must include in his gross income the excess contributiorls pursuan…
11. PLR 201351020 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsDec 20, 2013
    ements or betterments made to increase the value of any property. Section 1.263(a) - 4(d)(1) provides that except as provided in paragraph (f) of this section (relating to the 12 month rule), a taxpayer must capitalize amounts paid to create an intangible described in this paragraph (d). Section 1.263(a) - 4(d)(2) prov…
12. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001related by meaning
    penalty under section 6662(a) in order to intimidate petitioners, and (4) the issues remaining for decision in this case merely represent legitimate, substantive differences of opinion between petitioners and respondent. 52 On the record before us, we find that, in the event the computations under Rule 155 establish t…
13. T.C. Summary Opinion 2002-108 — Claudia J. Dunn v. Commissioner
    IRCCourt RulingsAug 22, 2002related by meaning
    T.C. Summary Opinion 2002-108 UNITED STATES TAX COURT CLAUDIA J. DUNN, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5131-01S. Filed August 22, 2002. Claudia J. Dunn, pro se. Rollin G. Thorley , for respondent. WOLFE, Special Trial Judge : This case was heard pursuant to the provisions of secti…
14. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003related by meaning
    …e carefully scrutinize transactions between related parties, Maxwell v. Commissioner , 95 T.C. 107, 116 (1990); C.M. Gooch Lumber Sales Co. v. Commissioner , 49 T.C. 649, 656 (1968), remanded pursuant to stipulation of the parties 406 F.2d 290 (6th Cir. 1969), and that the service agreement between Clarkston and J.D. w…
15. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    …fying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
16. 110 T.C. No. 1 — Nurit Haramgaal v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    nice Spetz 8,724 15342-96 Robert C. and Mary D. Borman 16,462 17606-96 Nurit Haramgaal 11,405 17607-96 John S. Husmann and Elinor C. MacKinnon 4,606 1 A notice of deficiency was issued to Alice M. Johnson and her husband Duaine E. Johnson. Mr. Johnson died on Sept. 1, 1994. An estat e was not opened for him. Alice M. J…
17. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
18. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    T.C. Memo. 2012-104 JNITED STATES TAX COURT JERALD W. WHITE AND CLAUDIA K. WHITE, Petitioners y. COMMISSIONER OF INTERNAL REVENUE, Respondent DIOGENES HOLDINGS, INC., Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 22514-07, 22515-07. Filed April 11, 2012. David E. Price and Adria S. Price, for p…
19. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
20. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    tter of local law and a State court's determination with regards to such assignment is not reviewable by this Court);9 Chambers v. Commissioner, supra 9This Court recognizes that in Commissioner v. Estate of Bosch, 387 U.S. 456, 465 (1967), the Court held that where the Federal estate tax liability turns upon the chara…