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1. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
   IRCCourt RulingsJul 15, 2026
   and the fair market value of the 377.74 acres of land in Madison County, A labama, after being encumbered by the conservation easement is $640,000. 5 and would make a smart investment. When it purchased the Parent Parcel, DESE Properties was aware that there were rock formations on the land. DESE Properties used the P…
2. T.C. Memo. 2006-106 — Susan F. Mostafa v. Commissioner
   IRCCourt RulingsMay 15, 2006
   …ION HAINES, Judge: Respondent determined a deficiency in petitioner's 1996 Federal income tax of $1,377 and additions to tax of $310 and $344 under section 6651(a)(1) and (2), respectively.¹ 1 All section references are to the Internal Revenue Code, (continued...) SERVED MAY 1 5 2006 - 2 - After concessions,2 the issue…
3. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
   IRCCourt RulingsFeb 18, 1998
   …en Point $250,651 Keogh Green Point 50,130 Keogh Green Point 13,939 IRA Apple 153,828 Keogh Apple 6,377 IRA Apple 5,489 IRA Total $480,414 Green Point and Apple withheld Federal income tax from the distributions of $50,130.00 and $153,828.00, respectively, in the amounts of $12,532.58 and $30,765.62, respectively. Peti…
4. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
   IRCCourt RulingsJun 17, 1997
   … Tax Penalty Sec. Sec. Year Deficiency 6651(a)(1) 6662(a) 1989 $34,000 --- $6,800 1990 21,883 --- 4,377 John N. Booth & Debra Booth (J&D Booth), docket No. 2546-94 Addition to Tax Penalty Sec. Sec. Year Deficiency 6651(a)(1)
5. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
   IRCCourt RulingsAug 27, 2026
   … of services as an employee constitutes a trade or business. Primuth v. Commissioner , 54 T.C. 374, 377 (1970) .
6. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
7. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
   IRCCourt RulingsOct 9, 1997related by meaning
   einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
8. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
   IRCCourt RulingsMay 3, 1995
   …of the 1984 taxable year, the National Presto veba had incurred but unpaid claims in the amount of $377,225, which amount exceeded the amount of cash held by the VEBA ($19,908) by $357,317. There is no evidence in the record to show that, as of the close of the taxable year 1984, petitioner was liable for any amount in…
9. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
   IRCCourt RulingsJan 9, 1985related by meaning
   erest) on the dates shown was as follows: Bate Balance 8/31/78 $123,727.08 8/31/79 131,211.18 8/31/80 141,708.07 8/31/81 144,502.33 4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
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. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …00.[87] Another source suggests that the cost is higher, costing $24,373 to $38,015 for IVF and $61,377 for successful pregnancy via IVF.[88] Even less costly procedures like IUI can be several thousand dollars per treatment.[89]
12. T.C. Memo. 2005-67 — Laura D. Seidel v. Commissioner
    IRCCourt RulingsMar 31, 2005
    …hich is the total amount of the CASC 401(k) plan distribution ($2,058.50 x ($51,497 ÷ $77,000) = $1,377). that petitioner may claim a deduction for attorney’s fees in the amount of $1,377. 10 6. Audit Examination Section 7605(b) provides: No taxpayer shall be subjected to unnecessary examination or investigations, and …
13. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
14. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
15. T.C. Summary Opinion 2014-17 — Rebecca Smackey Hurd v. Commissioner
    IRCCourt RulingsFeb 25, 2014
    …g)(5) to cover both vested and nonvested employees. See H.R. Conf. Rept. No. 99-841(Vol. II), at II-377 (1986), 1986-3 C.B. (Vol. 4) 1, 377 ("[T]he determination of active participant status * * * is made without regard to whether an individual's rights under an employer-maintained retirement plan are nonforfeitable (i…
16. 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…
17. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
18. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
19. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    tever source derived, including (but not limited to) the following items: ******* (11) Pensions; SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
20. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …