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1. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
   IRCCourt RulingsAug 24, 1995★ strong match
   OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   er for calendar year 1993 except that the reference to "20% reduction" was changed to "50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA 1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this connection, prior to its amendment by OBRA …
3. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
   IRCCourt RulingsJul 30, 1985related by meaning
   Eanes as petitioner. In his answer, filed May 2,1985, respondent claimed an increased deficiency of $90 in excise tax pursuant to secs. 4973 and 6214. Sec. 219 has been amended to allow persons covered by qualified plans to take deductions for contributions to IRA’s in taxable years beginning after Dec. 31, 1981. See s…
4. T.C. Summary Opinion 2015-12 — John Sanger Ringbloom v. Commissioner
   IRCCourt RulingsFeb 23, 2015
   …th. Petitioner complied with the amended decree and transferred an interest in his IRA totaling $38,913 to Ms. Ringbloom in April 2009. While petitioner could not recall whether he had claimed a deduction on his 2009 Federal income tax return for alimony paid, respondent's records indicate that he did not. Petitioner t…
5. 90 FR 60432 — Transparency in Coverage
   IRCProposed Rules (FR)Proposed Dec 23, 2025
   …are expected to impose one-time implementation costs, totaling approximately 6.7 million hours and $913.7 million across all plans (TPAs on behalf of plans) and issuers. Together, this represents a first-year burden of roughly 7.8 million hours and $982 million in associated costs. In subsequent years, the burden is es…
6. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
   IRCCourt RulingsAug 28, 2008
   …unable to file the return within the prescribed time . - Crocker v' . Commissioner , 92 T .C . 899, 913 (1989) ; sec . 301 .6651-1(c)(1), Proved . & Admin . Regs . A taxpayer may have reasonable cause'for .failure to timely file a return where .the taxpayer 'experi :ences .an illness or incapacity that prevents .the .t…
7. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
   IRCCourt RulingsSep 30, 1991related by meaning
   o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
8. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
   IRCCourt RulingsJun 17, 1997
   …91 1992 1993 Yearend assets $100,018 $38,204 $40,435 $43,066 $43,256 Income 103 2,853 3,930 4,362 1,913 Expenses 114 14,667 1,699 1,731 1,723 Contributions 100,030-0 - - 0 - - 0 - - 0 - These forms also reported the payment of insurance commissions of zero, $7,793, zero, zero, and zero in the respective years from 1989…
9. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
   IRCCourt RulingsOct 9, 1997★ strong match
   …orp. v. Commissioner , supra , the taxpayer argued that during its 1987 tax year it contributed $26,913,158 for postretirement employee welfare benefits. The
10. T.C. Memo. 2020-147 — Ram Ratan Sharma & Shakuntala Sharma v. Commissioner
    IRCCourt RulingsOct 29, 2020
    …14. Respondent subsequently issued a notice of deficiency to petitioners in which he disallowed $20,913 of their claimed $26,877 Schedule E loss deduction, resulting in a deficiency in tax of $5,230. Respondent also determined the now-conceded accuracy-related penalty of $1,046 against petitioners under section 6662(a)…
11. 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…
12. T.C. Memo. 2025-7 — Sonji Marie Mosley v. Commissioner
    IRCCourt RulingsJan 22, 2025
    …e fair market value in 2009 was $340,000; and (7) the foreclosure generated a capital gain of $267 ,913. W ith respect to the North Carolina properties , petitioner indicated that (1) the original purchase prices were $120,000, $117,000, $105,200, and $102,400; (2) there were no downpayment and closing costs; (3) there…
13. 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…
14. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984
    …11.00 294.00 Daniel W. Cass, Jr. 1979 294.00 Earl R. Lueckel and Lois B. Lueckel 1978 6,722.11 1979 913.87 913.87 Frederic E. Saunders and Mary Alice Saunders 1978 1,897.00 304.50 William H. Strong and Ella K. Strong 1978 1979 1980 4,558.31 653.10 653.10 653.10 The issues for decision are as follows: (1) Whether any po…
15. 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…
16. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …54 health insurance issuers and 205 TPAs, the total one-time total hour burden is estimated to be 4,913,172 hours with an equivalent total cost of approximately $432,996,203. Table 3A—Total High-End Estimated One-Time Cost and Hour Burden for Internet-Based Self-Service Tool for Each Health Insurance Issuer or TPA Occu…
17. 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…
18. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
19. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …1) $666,641 2004 727,769 92,770 635,000 2005 424,681 (316,620) 741,300 2006 (266,866) (658,780) 391,913 2007 -0- 112 (l12) He also hired an employee-benefits lawyer named Timothy Stewart to review the Grant County Pension Plan and get it into compliance. Stewart quickly concluded that the plan didn't work. As soon as h…
20. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007related by meaning
    s were attributable to disability, or that the distributions otherwise qualify for an exception to the 10-percent additional tax. In fact, petitioners state on brief that "Petitioners do understand that petitioners have to pay 10% penalty tax on the amount stated above * * * This is consistent with IRC section 72(t) (1…