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…
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…
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).
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
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 …
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
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…
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…
IRCCourt RulingsNov 21, 2023
…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 …
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
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.…
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
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…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
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…
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…
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…
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…
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…
IRCCourt RulingsFeb 10, 1997related by meaning
Judicial Notice Motions.
- 4 -
Rule 201(f) of the Federal Rules of Evidence provides that
judicial notice may be taken at any stage of the proceeding. Petitioner's Judicial Notice Motions will be denied in this case,
however, because their many paragraphs constitute nothing more
than a hodgepodge of argument and statem…