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…
IRCCourt RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
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…
IRCPrivate Letter RulingsApr 10, 2015
…e not deductible because of the guarantee.
In Boston Elevated Railway Co. v. Commissioner , 16 T.C. 1084, 1111-12 (1951) , aff'd
on another issue , 196 F.2d 923 (1st Cir. 1952) , the S ervice argued that loss resulting
from the abandonment of an elevated railway structure was compensated for by
legislation (the Public …
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…
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
PLR 202503002 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJan 17, 2025
…e not deductible because of the guarantee.
In Boston Elevated Railway Co. v. Commissioner , 16 T.C. 1084, 1111-1112 (1951), aff'd
on another issue , 196 F.2d 923 (1st Cir. 1952), the Service argued that loss resulting
from the abandonment of an elevated railway structure was compensated for by
legislation (the Public C…
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
PLR 202445015 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsNov 8, 2024
…e not deductible because of the guarantee. In Boston Elevated Railway Co. v. Commissioner , 16 T.C. 1084, 1111-1112 (1951), aff'd
on another issue , 196 F.2d 923 (1st Cir. 1952), the Service argued that loss resulting
from the abandonment of an elevated railway structure was compensated for by
legislation (the Public C…
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…
PLR 202250013 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsDec 16, 2022
…re not deductible because of the guarantee.
In Boston Elevated Railway Co. v. Commissioner, 16 T.C. 1084, 1111-1112 (1951), aff'd
on another issue, 196 F.2d 923 (1st Cir. 1952), the Service argued that loss resulting
from the abandonment of an elevated railway structure was compensated for by
legislation (the Public Co…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1996-450
UNITED STATES TAX COURT
THEODORE SOURIS, P.C., A DISSOLVED CORPORATION,
AND THEODORE SOURIS, AS SUCCESSOR IN INTEREST
OF THEODORE SOURIS, P.C., Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 639-95. F…
PLR 201129029 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJul 22, 2011
…e not deductible because of the
guarantee.
In Boston Elevated Railway Co. v. Commissioner , 16 T.C. 1084, 1111-1112
(1951), aff'd on another issue , 196 F.2d 923 (1st Cir. 1952), the Service argued that loss
resulting f rom the abandonment of an elevated railway structure was compensated for
by legislation (the Public …
IRCCourt RulingsFeb 9, 2023★ strong match
… scheme does not reflect true taxable income.” And in Bausch &
Lomb Inc. v. Commissioner , 933 F.2d 1084 (2d Cir. 1991), aff’g 92 T.C.
525 (1989), the Commissioner used section 482 to adjust royalty rates
paid by an Irish subsidiary for the use of its parent company’s
manufacturing tec hnology and related intangibles t…
PLR 201117013 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsApr 29, 2011
… not deductible because of the
guarant ee.
In Boston Elevated Railway Co. v. Commissioner , 16 T.C. 1084, 1111-1112
(1951), aff'd on another issue , 196 F.2d 923 (1st Cir. 1952), the Service argued that loss
resulting from the abandonment of an elevated railway structure was compensated for
by legislation (the Public C…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsSep 29, 1992
…rd should stand unless it was arbitrary and capricious. Mailman v. Commissioner, 91 T.C. 1079, 1083-1084 (1988) (interpreting similar language in section 6661).
PLR 201105004 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsFeb 4, 2011
…sses were not deductible because of the
guarantee.
In Boston Elevated Rwy v. Commissioner , 16 T.C. 1084, 1111-1112 (1951), aff'd
on a nother issue , 196 F.2d 923 (1st Cir. 1952), the Service argued that loss resulting
from the abandonment of an elevated railway structure was compensated for by
legislation (the Public …
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…
PLR 201001016 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJan 8, 2010
…. Rul. 81 -
225, 1981-2 C.B. 12.
8
PLR - 131336-08
In Boston Elevated Rwy v. Commissioner , 16 T.C. 1084, 1111-1112 (1951), aff'd
on another issue , 196 F.2d 923 (1st Cir. 1952), the Service argued that loss resulting
from the abandonment of an elevated railway structure was compen sated for by
legislation (the Public …