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1. 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).
2. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
   IRCCourt RulingsNov 21, 2023★ strong match
   …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 …
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. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
5. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsFeb 28, 2024related by meaning
   years beginning after the date of enactment of the Act); id. § 311(b)(2), 136 Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received). “This is the highly reticul…
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. 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…
8. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
   IRCCourt RulingsJun 24, 2003related by meaning
   tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
9. 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…
10. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    e Tax Court (and the Tax Court shall have jurisdiction) to determine the appropriate relief available to the individual under this section * * * - 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4 This amendment applies "with respect to liability for taxes arising or remaining unpaid on or after …
11. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974related by meaning
    ew principal place of work. Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217. SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
12. 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.…
13. 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
14. 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…
15. 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…
16. 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…
17. 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…
18. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
19. 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…
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…