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1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
2. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
   ERISAFinal Rules (FR)Apr 25, 2024
   … of professional advice in mitigating the effects of financial illiteracy in retirement planning.” [629]
3. 124 T.C. No. 10 — John Michael Dunkin v. Commissioner
   IRCCourt RulingsMar 31, 2005
   …awable but was not paid because the employee spouse continued to work. In re Marriage of Gillmore , 629 P.2d 1 (Cal. 1981). As used in this Opinion, the term “nonemployee spouse” is the spouse with a community property interest in the retirement benefits of
4. 67 T.C. 167 — Quality Brands, Inc. v. Commissioner
   IRCCourt RulingsNov 8, 1976
   …ty Brands — 1972 Sammy Abraham. $23,900.00 $484.64 2.027 All other participants. 54,607.00 889.61 1.629 Beverage Sales — 1972 George Abraham. $24,000.00 $235.38 .981 All other participants. 128,681.83 814.00 .633
5. T.C. Memo. 2002-30 — Drew Allen Rayner v. Commissioner
   IRCCourt RulingsJan 28, 2002
   … submitted a Form 1040, Individual Income Tax Return, for 1998 on which he reported zero income, $5,629 in income tax withholding, and an overpayment for which he sought a $5,629 refund. He attached to his Form 1040 a signed statement consisting of two typewritten pages in which he made various arguments denying his du…
6. 89 T.C. 225; 89 T.C. No. 19 — Professional & Executive Leasing v. Commissioner
   IRCCourt RulingsAug 3, 1987
   …urnetta, O.D., P.A. v. Commissioner, 68 T.C. 387, 397 (1977); Packard v. Commissioner, 63 T.C. 621, 629 (1975). Sec. 31.3121(d)-l(c)(2), Employment Tax Regs., defines the common law employer-employee relationship as follows:
7. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
   IRCCourt RulingsNov 21, 2007
   …ation, on behalf of Norwest Bank MN NA IRA C/F Ramzy Kopty reporting rollover contributions of $411,629 .63 for 1998 . According to that form, the fair market value of petitioner's IRA account was $337,854 .33 . During 1999, petitioner's IRA earned dividend income in the aggregate amount of $6,093 .21 . During the year…
8. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
   IRCCourt RulingsAug 30, 1999related by meaning
   tions in his gross income for 1995. The only exception to section 408(d)(1) that might apply in the present case is section 408(d)(6), which provides: (6) Transfer of account incident to divorce.--The transfer of an individual's interest in an individual retirement account or an individual retirement annuity to his spo…
9. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
   IRCCourt RulingsJun 10, 1996
   Id. at 629. We stated: "Our conclusion that there was only a technical change in the employment relationship is supported by the fact that Dr. Burton continued performing the same services as a sole proprietor as he had performed in the corporate form." Id. at 629-630; see also Reinhardt v. Commissioner , supra (chang…
10. 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…
11. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …400.00 -0- -0- -0Federal Express 14.00 -0- -0- -0Miscellaneous -0- 14.00 -0- 14.00 Pool service -0- 629.50 -0- 629.50 12 Depreciation 14,969.00 296.00 296.00 -0- Total 28,939.91 7,147.83 4,591.86 2,555.97 The Charleston Property: 1989
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. 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…
14. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    … Mr. Carter Mr. Horner 1958 $12,955 1959 18,460 1960 20,732 1961 22,766 1962 27,467 1963 31,149 $18,629 1964 31,048 18,629 1965 42,064 31,138 1966 45,652 42,522 1967 85,659 66,125 1968 114,084 78,229 $26,111 1969 204,775 163,292 33,249 1970 331,196 265,829 45,276 Although the nondef erred compensation paid to the offic…
15. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005
    …); Simpson v. Commissioner , - 16 - 64 T.C. 974, 984 (1975); Packard v. Commissioner , 63 T.C. 621, 629 (1975); sec. 1.1402(c)-1, Income Tax Regs. Relevant factors courts consider to determine whether an employer/employee relationship exists between the service provider and the hiring party include: (1) The hiring part…
16. 84 FR 53579 — Real Estate Appraisals
    IRCFinal Rules (FR)Oct 8, 2019
    …e been expected to sell for $445,152 in December 2011, according to the Case-Shiller Index and $414,629 according to the FHFA Index. Table 1—House Price and Inflation Adjustments of $250,000 at June 30, 1994, for the Case-Shiller Index and the FHFA Index, and July 1, 1994 for the CPI Index Table 1 year Case-Shiller FHF…
17. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
18. 75 FR 5410 — Interim Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008
    IRCFinal Rules (FR)Feb 2, 2010
    …elve month use of mental health services in the United States.” Archives of General Psychiatry, 62, 629-640. The study found that 40 percent of people reporting mental health and substance use disorders receive some treatment in a year. Back to Citation 27.  Wang, P.S., Lane, M., Olfson, M., Pincus, H.A., Wells, K.B., …
19. PLR 201437021 — Minimum Funding Standards
    IRCPrivate Letter RulingsSep 12, 2014
    …ress below: Internal Revenue Service Manager, Actuarial Group 2 1111 Constitution Avenue, N.W. (NCA-629) Washington, DC 20224 If any one of the conditions written in Letter Ruling, as modified by this letter, is not satisfied, the approval to extend the amortization periods for amortizing the unfunded liabilities would…
20. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…