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69 documents · 0.19sAllIRCERISAPBGCJoint Board
  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. 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…
  3. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    y [section 403(a) of ERTA], then the amendment made by [section 403(a) of ERTA] shall not apply to the estate of such decedent. [1981-2 C.B. 326-327.] *295 Respondent asserts that all the conditions contained in section 403(e)(3) have been met. Therefore, *99 he maintains, petitioner is not entitled to an unlimited mar…
  4. T.C. Memo. 2014-31 — K.H. Company, LLC Employee Stock Ownership Plan v. Commissioner
    IRCCourt RulingsFeb 24, 2014
    …ral or directory and does not relate to the essence of the statute. Taylor v. Commissioner, 67 T.C. 1071, 1077-1078 (1977).
  5. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party (here respondent) . Sundstrand 4 On December 13, 2021, petit…
  6. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwhiler v. Commissioner, T.C. Memo. 2016-18, 111 T.C.M. (CCH) 1071, 1074. Petitioner has repeatedly advanced numerous frivolous positions in this
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    er for calendar year 1993 except that the reference to "20% reduction" was changed to "50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA 1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this connection, prior to its amendment by OBRA …
  8. T.C. Memo. 2012-166 — Todd R. & Andrea Pedersen v. Commissioner
    IRCCourt RulingsJun 13, 2012
    …td. v. United States, 291 F.2d 761, 768 (9th Cir. 1961)), aff'd without published opinion, 770 F.2d 1071 (3d Cir. 1985); see also House Beautiful Homes, Inc. v. Commissioner, 405 F.2d at 66 ("[I]t is only through an analysis of conduct that motivation can be inferred. Whether the conduct occurs immediately subsequent t…
  9. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM January 07, 2004 Number: 200424004 Release Date: 6/11/04 Third Party Contact: Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04 CASE-MIS No.: TAM- 127815-03, CC:ITA:B07 Industry Director ------------------------------------------------ Taxpayer's Name…
  10. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    IRCCourt RulingsNov 21, 2007
    …93 36 .1085 6,818 .47 1,608 .94 8,427 .4 1 1994 66 .0084 15,698 .12 1,725 .72 17,423 .8 4 1995 108 .1071 46,776 .86 6 .29 46,783 .1 5 1996 144 .5164 108,732 .69 30 .90 108,763 .5 9 1996 110,116 .148 0 1997 10,323 .9064 304,555 .24 10 .31 304,565 .5 5 'Number of shares restated to reflect a 70-to-1 stock split . After p…
  11. 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…
  12. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  13. T.C. Memo. 2003-194 — Edward A. Bougas, III v. Commissioner
    IRCCourt RulingsJul 2, 2003
    …ubstance or essence of the statute, they must be rigidly observed. Taylor v. Commissioner , 67 T.C. 1071, 1077 (1977); Sperapani v. Commissioner , 42 T.C. 308, 331 (1964). On the other hand, if the requirements are procedural or directory in that they do not go to the essence of the thing to be done, but rather - 8 - a…
  14. T.C. Memo. 2003-32 — Howard E. Clendenen v. Commissioner
    IRCCourt RulingsFeb 12, 2003
    …ommissioner , T.C. Memo. 1998-318 (docket No. 18155-96R) (the declaratory judgment), affd. 207 F.3d 1071 (8th Cir. 2000). We held that the trust was not a qualified trust under section 401(a) beginning with the plan year 1986 because the annual additions exceeded the limitations of section 415(c) when we found that the…
  15. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019
    …r, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, 111 T.C.M. (CCH) 1071, 1074. Petitioner has raised many frivolous arguments during this litigation. We sanctioned him on two prior occasions for advancing frivolous arguments, and in this case we repeatedly warned him to desist from doin…
  16. T.C. Memo. 2006-101 — Eugenie Denise Mitchell v. Commissioner
    IRCCourt RulingsMay 11, 2006related by meaning
    T. C. Memo. 2006-101 CA l STA UNITED STATES TAX COURT . . EUGENIE DENISE MITCHELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7144-04. Filed May ll, 2006. Eugenie Denise Mitchell, pro se. Margaret A. Martin· and Daniel J. Parent, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, …
  17. T.C. Memo. 2025-7 — Sonji Marie Mosley v. Commissioner
    IRCCourt RulingsJan 22, 2025
    …dler v. Commissioner, 75 T.C. 1, 20– 21 ( 1980) ( quoting Es tate of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960)). Petitioner has not argued that any of the statutory exceptions under section 6654(e) applies , and none apply . Accordingly, we find that petitioner is liable for the addition to tax under section 665…
  18. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
  19. T.C. Memo. 2000-171 — Van Roekel Farms, Inc. v. Commissioner
    IRCCourt RulingsMay 24, 2000
    …dependent contractor working for the taxpayer, Howard E. Clendenen, Inc. v. Commissioner , 207 F.3d 1071 (8th Cir. 2000), affg. T.C. Memo. 1998-318. We follow that holding and conclude that the management fees paid to Mr.
  20. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…