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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   efinition of an applicable foreign legal restriction and the taxpayer has elected the deferred income method of accounting, any section 482 allocation connected with the transaction will be defer rable until the restriction is removed. Deductions and credits chargeable against a deferred amount are subject to deferral …
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. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
   IRCCourt RulingsAug 8, 1996★ strong match
   …W. AND SUZANNE M. COFFIELD, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1205-95. Filed August 8, 1996. Timothy W. and Suzanne M Coffield, pro se. Mark S. Mesler , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Carleton D.…
4. T.C. Memo. 1997-34 — Mark J. & Mary A. Fuhrman v. Commissioner
   IRCCourt RulingsJan 21, 1997
   …ase, focused precisely on this point in Porter v. Commissioner , 88 T.C. 548 (1987), revd. 856 F.2d 1205 (8th Cir. 1988), affd. on other grounds sub nom. Adams v. Commissioner , 841 F.2d 62 (3d Cir. 1988). In Porter v. Commissioner , supra , we considered whether for purposes of section 219(g), Federal judges appointed…
5. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
   IRCCourt RulingsJan 3, 2011related by meaning
   nclude in gross income the cash value of a life insurances policy held, by a multiemployer Unless otherwise indicated, -section refer.ences are to the Internal oRevenue Code o f . 198 6 ( Code ) as amende d and in e f f ec t for the year sin issue, andrRule- references are t o the Tax Court Rules of Practicemand Proced…
6. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
   IRCCourt RulingsAug 13, 1999related by meaning
   penses which are ordinary and necessary and recurring in nature. Respondent relies on Rev. Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring expenses paid by an employer are not deductible under this regulation. We disagree. Our analysis starts at s…
7. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
   IRCCourt RulingsAug 27, 2026
   … objective of making a profit. Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), aff ’ d , 702 F.2d 1205 (D.C. Cir. 1983) (unpublished table decision) ; Golanty v. Commissioner, 72 T.C. 411, 425 – 26 (1979), aff ’ d , 19 We direct Mr. Janangelo’s attention to Treas ury Reg ulation § 1.212- 1(f): “ Among expenditures no…
8. 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…
9. T.C. Memo. 2021-107 — Gayle Gaston v. Commissioner
   IRCCourt RulingsSep 2, 2021
   … 183; Dreicer v. Com m issioner, 78 T.C. 642, 645 (1982), aff’d without published opinion, 702 F.2d 1205 (D.C. Cir. 1983); see also sec. 6001; sec. 1.6001-1(a), Incom e Tax Regs. Respondent has conceded - 8 - [*8] that petitioner actually paid the reported expenses. We therefore m ust determ ine only whether the expens…
10. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
11. 46 T.C. 706 — Schlegel v. Commissioner
    IRCCourt RulingsAug 31, 1966
    …2d 613 (C.A. 7, 1960) ; William S. Bolden, 39 T.C. 829 (1963) ; Estate of Edward I. Rieben, 32 T.C. 1205 (1959) ; Clarence F. Buckley, 29 T.C. 455 (1957). Where, however, there is a change of employer accompanied by such a transfer of beneficial ownership, the requirement is met, at least where the acquiring new employ…
12. 148 T.C. No. 22 — Steven M. Petersen & Pauline Petersen v. Commissioner
    IRCCourt RulingsJun 13, 2017
    …onding inclusion in income." H.R. Rept. No. 98-432 (Part 2), at 1578 (1984), 1984 U.S.C.C.A.N. 697, 1205. -14Section 267(b) generally defines the "relationships" that bring the statute into play. Before 1978 transactions between S corporations and their shareholders were exempt from its coverage unless the shareholder …
13. T.C. Memo. 2000-137 — Alton F. Emerson v. Commissioner
    IRCCourt RulingsApr 12, 2000
    …(1983); Dreicer v. Commissioner , 78 T.C. 642, 645 (1982), affd. without published opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs. While a taxpayer's expectation of profit need not be reasonable, there must be a good-faith expectation of making a profit. See Allen v. Commissioner , 72 T.C. 28,…
14. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    tinued...) - 5 - of the Secretary, and in the same manner as taxes. Sec. 6652(c) (4) (A). Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and demand, the Secretary can collect the tax by levy upon the property belonging to the person, subject to …
15. T.C. Memo. 2012-311 — Charles L. Hartley v. Commissioner
    IRCCourt RulingsNov 6, 2012related by meaning
    oneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). However, the Commissioner bears the burden of proof with respect to any increase in deficiency. See Rule 142(a)(1). Our conclusion, however, is based on a preponderance of the evidence, and thus the allocation of the burden of proof is immaterial. See E…
16. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013related by meaning
    s amount includes the additional tax of $32,137 under sec. 72(t). - 27 - [*27] that the determination of reasonable cause and good faith "is made on a case-by-case basis, taking into account all pertinent facts and circumstances." Sec. 1.6664-4(b)(1), Income Tax Regs. The parties have agreed in the stipulation of settl…
17. T.C. Memo. 1996-146 — Lloyd Patterson v. Commissioner
    IRCCourt RulingsMar 25, 1996
    …making a profit." Dreicer v. Commissioner , 78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983). The taxpayer's expectation of earning a profit need not be reasonable, but the taxpayer must establish that the activities were continued with a bona fide profit objective. Dreicer v. Commissioner …
18. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    ximum of 46% of the combined income to the FSC (by adjusting the sale 1 transfer price). If the profit margin was between 3.98% and 7.96%, the maximum amount of taxable income assignable varied inversely from 46% to 23%, respectively. If the profit margin exceeded 7.96%, they could assign a maximum of 23% of the combin…
19. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …st. Dreicer v. Commissioner, 78 T.C. 642, 644-645 (1982), aff'd without published opinion, 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs. Whether a taxpayer has an actual and honest profit - 10 - [*10] objective is a question of fact to be answered from all of the relevant facts and circumstances. Ha…
20. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…