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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. 74 T.C. 651 — Judd v. Commissioner
   IRCCourt RulingsJul 8, 1980related by meaning
   minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
3. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
   IRCCourt RulingsMay 29, 2002related by meaning
   is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
4. Court of Appeals for the Tenth Circuit — Phillips v. Boilermaker-Blacksmith National Pension Trust
   ERISACourt RulingsSep 29, 2026
   …Labor’s regulations just because we might disagree with them. See Montaro- Vega v. Holder, 721 F.3d 1175, 1178 (10th Cir. 2013) (“W e do not . . . undo administrative regulations just because they may not be to a litigant’s liking or our own.”). Appellate Case: 25-3160 Document: 60-1 Date Filed: 09/29/2026 Page: 16 17 …
5. 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…
6. T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner
   IRCCourt RulingsFeb 23, 2022
   …may exercise jurisdiction only to the extent authorized by Congress. Judge v. Commissioner, 88 T.C. 1175, 1180 – 81 (1987); Naftel v. Commissioner, 85 T.C. 527, 529 (1985). We nevertheless have jurisdiction to determine whether we have jurisdiction. Hambrick v. Commissioner, 118 T.C. 348, 350 (2002); Pyo v. Commissione…
7. 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…
8. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
   IRCCourt RulingsJun 18, 1999
   …urisdiction only to the extent expressly authorized by statute. See Judge v. Commissioner , 88 T.C. 1175, 1180-1181 (1987); Naftel v. Commissioner , 85 T.C. 527, 529 (1985). This Court's jurisdiction - 8 - to redetermine a deficiency in tax generally does not extend to statutory interest imposed under section 6601. See…
9. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
   IRCCourt RulingsJul 29, 1997
   …ase of an overpayment of an addition to tax under sec. 6654(a), see Judge v. Commissioner , 88 T.C. 1175, 1186-1187 (1987). no return is filed for the taxable year . 1 See sec. 6665(b)(2); Meyer v. Commissioner , 97 T.C. 555, 562 (1991) (citing Fendler v.
10. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
11. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
12. T.C. Memo. 2017-139 — Louelia Salomon Frias & Mervyngil Salomon v. Commissioner
    IRCCourt RulingsJul 11, 2017
    …rt that statements made in briefs do not constitute evidence); Reiff v. Commissioner, 77 T.C. 1169, 1175 (1981). Petitioners also contend that if section 1.72(p)-1, Income Tax Regs., does not apply, there was no distribution because: (1) all parties to the loan acted as though they agreed to suspend payments; (2) the s…
13. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989related by meaning
    e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
14. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014
    …may exercise jurisdiction only to the extent authorized by Congress. Judge v. Commissioner, 88 T.C. 1175, 1180-1181 (1987); Naftel v. Commissioner, 85 T.C. 527, 529 (1985). The Tax Court is without authority to enlarge upon that statutory grant. See Phillips Petroleum Co. v. Commissioner, 92 T.C. 885, 888 (1989). We ne…
15. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
16. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …strain myself as well." See Antonin Scalia, "The Rule of Law as a Law of Rules," 56 U. Chi. L. Rev. 1175, 1179 (1989). Judge Lauber in his concurrence ignores my bright-line rule; he says instead that I would create a new rule of law "out of whole cloth, specifically designed to suit the peculiar facts of this case." S…
17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
18. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014
    …may exercise jurisdiction only to the extent authorized by Congress. Judge v. Commissioner, 88 T.C. 1175, 1180-1181 (1987); Naftel v. Commissioner, 85 T.C. 527, 529 (1985). The Tax Court is without authority to enlarge upon that statutory grant. See Phillips Petroleum Co. v. Commissioner, 92 T.C. 885, 888 (1989). We ne…
19. 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…
20. 88 FR 87968 — Definition of “Employer”-Association Health Plans
    ERISAProposed Rules (FR)Proposed Dec 20, 2023
    …' within the meaning of ERISA”). Back to Citation 72.   Baucom v. Pilot Life Ins. Co., 674 F. Supp. 1175, 1180 (M.D.N.C. 1987). In Baucom, “[r]eturning to ERISA's language, the court observe[d] that, despite its limitations, the statutory definition of `employee' mandates that an employee must work for another.” Id. (c…