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1. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
   IRCCourt RulingsAug 27, 2026
   …o weeks , except for the month of December. In December 2018 she wrote him three checks totaling $1,812 : $900, $ 812 , and $ 100. Each check was made out to Mr. Janangelo personally . 9 Mr. Janangelo appeared on his own behalf and for Mrs. Janangelo as her attorney of record. We call Mr. Janangelo’s attention to Rule …
2. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
   IRCCourt RulingsMay 29, 1968
   …nt was, during the period of time relevant to the issue herein, the Soft Drink Workers Union, Local 812 (hereinafter referred to as local 812). Leo Greenfield, an attorney, represented local 812 in its negotiations with petitioner at all times relevant to the issue herein. Petitioner entered into its first collective-b…
3. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
   IRCCourt RulingsSep 18, 1996
   …r 1989, petitioners disclosed the receipt of the taxable portion of the Transfer Refund; i.e., $227,812. Of this amount, petitioners reported that $77,812 was taxable and that the balance, or $150,000, had been rolled over tax-free into an IRA. Petitioners attached Form 5329 "Return for Additional Taxes Attributable to…
4. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003related by meaning
   ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
5. 90 FR 60432 — Transparency in Coverage
   IRCProposed Rules (FR)Proposed Dec 23, 2025
   …his figure is calculated by multiplying the annual cost per user after the file-size reduction ($79,812) by the number of third-party developers and other file users (300): $79,812 × 300 = $23,943,600. Back to Citation 210.
6. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
   IRCCourt RulingsSep 30, 1985related by meaning
   nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
7. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
   IRCCourt RulingsMar 9, 2011
   …a manner most favorable to the party opposing summary judgment.. Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v. Commissioner, 79 T.C. 340, 344 (1982). The adverse party.must
8. 115 T.C. No. 19 — Flahertys Arden Bowl, Inc. v. Commissioner
   IRCCourt RulingsSep 25, 2000related by meaning
   lity for the excise taxes and that petitioner was liable for the additions to tax under section 6651(a)(1). Discussion I. Liability Under Section 4975 A. The Statutes Section 4975 was added to the Internal Revenue Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003…
9. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
   IRCCourt RulingsJul 22, 1980related by meaning
   y for purposes of applying such section. * * * Sec. 83(a) and (c)(1) states: SEC. 83. PROPERTY TRANSFERRED IN CONNECTION WITH PERFORMANCE OF SERVICES. (a) General Rule. — If, in connection with the performance of services, property is transferred to any person other than the person for whom such services are performed,…
10. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
11. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    …st rate and 5.82% for the second segment interest rate. (ii) A shortfall amortization base of −$379,812 is established for 2016, which is equal to the $2,500,000 funding target, reduced by the sum of $2,450,000 of assets, $316,696 (the present value of the remaining installments with respect to the 2015 shortfall amort…
12. 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…
13. 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…
14. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
15. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …d section 6662A as part of the American Jobs Creation Act of 2004 (AJCA), Pub. L. No. 108-357, sec. 812(a), 118 Stat. at 1577. Section 6662A imposes a 20% accuracy-related penalty on reportable transaction understatements and is effective for taxable years ending after October 22, 2004. See sec. 6662A(a); seeialso AJCA…
16. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    s in order to comply with their FATCA obligations, unless the FFIs qualify for an exemption under the FATCA regulations. Notice 2016–48 Notice 2016–48 This Notice explains how the IRS will implement the changes to the Individual Taxpayer Identification Number (ITIN) program resulting from the enactment of the Protectin…
17. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    IRCCourt RulingsJan 16, 2020
    … -3Background3 During the year in issue Mrs. Merrell received Social Security benefits totaling $26,812, including benefits of $9,772 that were otherwise payable to her in 2014, and Mr. Merrell received a distribution of $17,410 from an IRA. Mr. Merrell had not attained the age of 59½, nor was he disabled during the ye…
18. T.C. Memo. 1996-189 — Marcus Wayne & Judith Caroline Ramsey v. Commissioner
    IRCCourt RulingsApr 18, 1996
    … letter from Bancsure to petitioner dated Mar. 31, 1989, refers to a total severance payment of $61,812.50, of which $6,812.50 represented expense reimbursement and pension payments. The letter makes no allocation of the $6,812.50 as between expense reimbursement and pension payments. established a SEP for petitioner’s…
19. 98 T.C. 503; 98 T.C. No. 34 — Fowler v. Commissioner
    IRCCourt RulingsApr 22, 1992related by meaning
    tatutoiy references are to the Internal Revenue Code in effect for 1986, and all Rule references are to the Tax Court Rules of Practice and Procedure. he parties have stipulated as follows: 8. During 1986, the petitioner, due to his termination of employment * * * received a total distribution from his employer's Incen…
20. 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…