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1. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
   IRCCourt RulingsApr 2, 2024related by meaning
   , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
2. T.C. Memo. 2020-101 — Tamecca Seril a.k.a. Tamecca Tillard v. Commissioner
   IRCCourt RulingsJul 8, 2020
   …ouse $19,092 during 2016, consisting of $9,283 distributed to Morehouse from her 529 account and $9,809 in payments separately documented by her bank statements. We find that $5,816 of the latter sum represented the balance of her withdrawals from the section 529 account (viz., the portion distributed to her rather tha…
3. T.C. Memo. 2010-146 — Peggy Ann Sears v. Commissioner
   IRCCourt RulingsJul 6, 2010
   …petitioner received distributions totaling'$60,937 as follows : $24,689 from account No . 8052, $18,809 from account No . 9853,6 and $17,439 from account No . 9052 .' In 2006 petitioner was not yet 59-1/2 years old . Petitioner filed her 2006 Form 1040 ., U .S . Individual Income Tax' Return, -electronically ."' Petiti…
4. PLR 201128017 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
   IRCPrivate Letter RulingsJul 15, 2011
   …Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 494 (1984), the controlling provision was § 809(c)(1). Thi s provision was interpreted by § 1.809-4(a)(1)(i), which provided that The term “gross amount of all premiums” means the premiums and other consideration provided in the insurance or annuity contract. Thus…
5. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
6. PLR 201105005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
   IRCPrivate Letter RulingsFeb 4, 2011
   …fer of property in an assumption reinsu rance transaction as defined in paragraph (a)(7)(ii) of § 1.809-5). The term also includes amounts a life insurance company charges itself representing premiums with respect to liability for insurance and annuity benefits for its employees (including full-time life insurance sale…
7. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
   IRCCourt RulingsAug 6, 1996★ strong match
   by section 404(a)(6), and are therefore not deductible in that year. To reflect the foregoing and issues previously resolved, Decision will be entered under Rule 155 .
8. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
   IRCCourt RulingsMay 25, 2005★ strong match
   s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
9. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
   IRCCourt RulingsMar 10, 2020
   …ation for the statutory distinction. McDonald v. Board of Election Com'rs of Chicago, 394 U.S. 802, 809 (1969). Estate of Kunze v. Commissioner, 233 F.3d 948, 954 (7th Cir. 2000), § T.C. Memo. 1999-344.5 This Court follows the same framework in evaluating equal protection claims regarding statutes affecting economic ri…
10. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ons of the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. - 3 - After concessions, the following 2 issues remain for us to resolve in the present proceeding: (1) Whether petitioner, in its taxable year ending January 30, 1988 (TYE 88…
11. 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…
12. 34 T.C. 73 — Zeltzerman v. Commissioner
    IRCCourt RulingsApr 18, 1960
    …ddition to what he had agreed to accept, namely, $1,000 per month. The case of Howard. Veit, 8 T.C. 809, also cited by the petitioner, is similarly distinguishable.
13. 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…
14. 77 T.C. 97; 2 Employee Benefits Cas. (BNA) 1678 — Miller v. Commissioner
    IRCCourt RulingsJul 23, 1981
    …aph (B)).” Sec. 2(3), Self-Employed Individuals Tax Retirement Act of 1962, Pub. L. 87-792,76 Stat. 809,811. For an explanation of the effect of sec. 911(b) on "earned income” under present law as compared with prior law (prior to sec. 204(c), Foreign Investors Tax Act of 1966, Pub. L. 89-809,80 Stat. 1539,1577, effect…
15. 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…
16. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    …nerships. On brief, petitioners attached documents which purport to summarize loans totaling $1,042,809.42 - 12 - 8 The "Officer Loan Payable" account shows a number of "loans" from Mr. Bach to ISI and shows payments either to Mr. Bach or to other vendors on behalf of Mr. Bach. The beginning balance of the Officer Loan…
17. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
18. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
19. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
20. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …Supp. I 2013)) (all using the phrase "against equity and good conscience"). In Groseclose v. Bowen, 809 F.2d 502 (8th Cir. 1987), the court considered the meaning of "against equity and good conscience" as it appears in 42 U.S.C. sec. 404(b) (relating to adjustment or recovery of Federal old-age, survivors, and disabil…