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1. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
   IRCCourt RulingsOct 9, 1997★ strong match
   einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
2. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
   IRCCourt RulingsMar 5, 2018related by meaning
   of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
3. 37 T.C. 78 — Hayward v. Commissioner
   IRCCourt RulingsOct 25, 1961
   …s that your share of the distributable net loss for the year February 1 to December 31, 1952 is $55,806.31. Inasmuch as you reported a net loss of $72,784.81, your taxable income is increased $16,978.50, computed as follows: Ordinary net loss per partnership return_ ($206,046.41) Add: Wages paid in contravention of the…
4. 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…
5. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
   IRCCourt RulingsOct 19, 2010
   … after having been informed that his basis * * * is groundless." Greenberg v. Commissioner, 73 T.C. 806, 814 (1980). In Dew v. Commissioner, 91 T.C. 615, 626 (1988), the Court imposed a I section 6673 penalty against taxpayer, when he "persisted in
6. 58 T.C. 241 — Estate of Kleemeier v. Commissioner
   IRCCourt RulingsMay 8, 1972
   …annuity were as follows: Percent Northwestern University_ $337. 56 3. 10 Washington. University- 3, 806. 09 34. 93 Robert W. Kleemeier_ 6, 753. 16 61. 97 Total_ 10, 896. 81 100. 00 Robert and Washington University each contributed to the premium cost of the CREF annuity. The contribution of each, the percentage contrib…
7. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
   IRCCourt RulingsJun 10, 2002related by meaning
   T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
8. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   gs in the Court, as follows: Trucking Company Client Case at Docket No. John and Kimberly Kohler 1026-01 (NBS Trucking) Joseph and Barbara Hix 1062-01 (Joe Hix Trucking) Blachowske Truck Line, Inc. 1107-01 Jones Brothers Trucking, Inc. 1149-01 Lake State Transport, Inc. 1286-01 Schak Trucking Inc. 1287-01 Donald Fierec…
9. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
   IRCRegulationsSep 9, 2016
   … 65 19.5 6.97% $5,897.88 66 20.5 6.90% 5,524.69 67 21.5 6.84% 5,164.63 68 and over Varies Varies 50,806.92 Total 67,394.12 (iii) Applying the 5% probability of withdrawal, the portion of the funding target for the 2009 plan year attributable to Participant E's assumed withdrawal at age 50 is $3,369.71 ($67,394.12 × 5%)…
10. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
11. 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…
12. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …dence.4 The Court need not and does not decide whether the Handbook is admissible under rule 807 or 806 of the Federal Rules of Evidence. Because the Court finds for respondent without it, the Court need not consider the Handbook in reaching a decision.5 FINDINGS OF FACT Some of the facts have been stipulated and are s…
13. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …c, Inc . , 758 F . Supp . 543, 544, 551 (D .S .D . 1991) ; Deppisch v . United States , 227 Bankr . 806, 808-09 (Bankr . S .D . Ohio 1998) . This gives the IRS the power to seize taxpayers' property held in an IRA . See secs . 6331-6334 ; Kane v . Capital Guardian Trust Co . , 145 F .3d 1218, 1223 (10th Cir . 1998) (ri…
14. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
15. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    … with significant alterations, was placed in to section 45 of the Revenue Act of 1928, 45 St at. at 806. The other consolidated-return provisions of the Revenue Act of 1926 were placed into sections 141 and 142 of the Revenue Act of 1928, 54 Stat. at 831- 832. See G.D. Searle & Co. v. Commissioner , 88 T.C. at 356. 41 …
16. T.C. Memo. 1997-487 — Richard Walter Drake v. Commissioner
    IRCCourt RulingsOct 28, 1997
    …t of $78. As a result of these adjustments, respondent increased petitioner's taxable income by $17,806. Respondent disallowed petitioner's deduction for an IRA contribution in full. In addition, respondent determined that petitioner was liable for an accuracy-related penalty of $534 pursuant to section 6662(a) for neg…
17. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012related by meaning
    , petitioners contend, because they contributed at least that amount in each of those years to qualified plans and claimed corresponding deductions on their joint returns for those years. As petitioners see it, they may deduct any amount claimed on those returns as a retirement plan contribution because the notices of …
18. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …ctually commenced. - 18 - [*18] See McKelvey v. Commissioner, T.C. Memo. 2002-63, afCd, 76 F. App'x 806 (9th Cir. 2003). "Until that time, expenses related to that activity are not 'ordinary and necessary' expenses currently deductible under section 162 (nor are
19. T.C. Summary Opinion 2011-71 — Joseph B. & Rosemary A. Niesen v. Commissioner
    IRCCourt RulingsJun 16, 2011related by meaning
    ns allowed by this subtitle which are attrib table to such trade or business". Compensation excludes any amounts received as interest and dividends, a pension or annui y, and Social Security benefits. Secs. 219(f) (1), 401(c (2), 86(f) (3); see Miller v. Commissioner, 77 T.C. 97, 102 (1981). The other adjustments in th…
20. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    luded that the bulk of the $26 million received by hi s IRA was attributable to his relinquishment of rights under the non- ESOP deferred compensation plans, which were not eligible for tax-free rollover. It accordingly determined t hat $25,132,892 of the $26 million constituted an “excess contribution” to his IRA unde…