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86 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  2. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986★ strong match
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  3. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …. 5754-94 Addition to Tax Penalty Sec. Sec. Year Deficiency 6651(a)(1) 6662(a) 1989 $12,744 $637 $2,549 Howard S. Young & Elaine P. Young (the Youngs), docket No. 5755-94 Addition to Tax Penalty Sec. Sec. Year Deficiency 6651(a)(1) 6662(a) 1989 $14,008 --- $2,802 Bruce E. Traegde & Patricia Traegde (the Traegdes), dock…
  4. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  5. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  6. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    g at the time of retirement”. G en. Signal Corp. v. Commissioner , 142 F.3d at 549 (citing Parker-Hannifin Corp. v. Commissioner , 139 F.3d 1090, 1094 (6th Cir. 1998)). We agree with respondent that the funding of the reserve cannot begin until the reserve is created. However, we do not agree with respondent that the r…
  7. T.C. Memo. 2004-40 — Anthony J. & Denise D. Sadberry v. Commissioner
    IRCCourt RulingsFeb 18, 2004
    …adhered to the $6,154.94 penalty that petitioners self-assessed on their amended return for the $61,549.38 taxable portion of early distributions by Southern Farm Bureau and Glenbrook.. Respondent included the previously unreported SFB and Glenbrook distributions as gross income, determined that self-employment tax was…
  8. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …ership taxable income of $840,069 for 1987. This consisted of $637,316, one-fourth of the - 45 - $2,549,264 deferred income that it was allocating over 4 years, plus $231,253 in accrued interest payable from MPC, less $28,500--a management fee expense to BBPA. On its partnership return for 1988, MIT 82 reported partner…
  9. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    United States Tax Court T.C. Memo. 2022-69 CLAIR R. COUT URIER, JR. , Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent ————— Docket N o. 19714-16. Filed July 6, 2022. ————— Alvah Lavar Taylor and Daniel W. Soto , for petitioner. Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and Edward T.…
  10. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    …,100 1966. 9,235 Year Cash dividends 1967. $10,844 1968. 17,800 1969. 20,399 1970 . 27,988 1971. 63,549 1972. 1,800,274 1973 . 313,863 1974 . 470,495 1975 . 544,895
  11. 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 …
  12. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979★ strong match
    …r. 1949), revg. a Memorandum Opinion of this Court; Coe Laboratories, Inc. v. Commissioner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960).
  13. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    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…
  14. 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…
  15. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
    IRCCourt RulingsSep 21, 1962
    …ution was adopted: Whereas, the books oí account of the Exchange now show that the Exchange had $55,549.11 on hand as of December 31, 1944, oyer and above the cost of insurance subscribers, and it is deemed to be to the best interests of the subscribers that said sum be distributed pro rata in cash to the subscribers o…
  16. 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…
  17. 88 FR 65888 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCProposed Rules (FR)Proposed Sep 26, 2023
    …00-$700 and $268-$938, respectively. Certified IDR entities currently charge a median fixed fee of $549 for single determinations and $770 for batched determinations in 2023. As such, for approximately 108,000 single determinations and 24,840 batched determinations annually,[92]
  18. T.C. Memo. 1998-399 — Ronny H. & Charlotte A. Schmalzer v. Commissioner
    IRCCourt RulingsNov 10, 1998related by meaning
    tstanding rollover involved in this case. Accordingly, the amount of excludable basis in the instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is $1,950 and the denominator of which is $1,374.53 plus $6,100, resulting in an amount excludable of $1,591.40.…
  19. T.C. Memo. 2013-271 — Christine C. Peterson & Roger V. Peterson v. Commissioner
    IRCCourt RulingsNov 25, 2013
    …97-386; Commissioner v. Danielson, 378 F.2d 771, 775 (3d Cir. 1967), vacating and remanding 44 T.C. 549 (1965). Accordingly, the 2009 FSP and GFP distributions are subject to self-employment tax pursuant to section 1401. - 10 - [*10] Contentions we have not addressed are irrelevant, moot, or meritless. To reflect the f…
  20. T.C. Summary Opinion 2013-42 — Aster Tirfe v. Commissioner
    IRCCourt RulingsJun 3, 2013related by meaning
    T.C. Summary Jpinion 2013-42 UNITED STATES TAX COURT ASTER TIRF E, Petitioner v. COMMISSIONER OF INTE 1NAL REVENUE, Respondent Docket No. 25865-10S. Filed June 3, 2013. Aster Tirfe, pro se. Steven Roth, for respondent. SUMMARlY OPINION CARLUZZO, Special Trial Judge This case was heard pursuant to the provisions of sect…