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Go to 98 T.C. 294 (not yet in the library — opens the official source)
89 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2003-294 — Randolph S. Simpson, I v. Commissioner
    IRCCourt RulingsOct 21, 2003
    1 Unless otherwise indicated, section references are to (continued...) T.C. Memo. 2003-294 UNITED STATES TAX COURT RANDOLPH S. SIMPSON, I, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2832-01. Filed October 21, 2003. Randolph S. Simpson I, pro se. Gordon P. Sanz , for respondent. MEMORANDUM OP…
  2. T.C. Summary Opinion 2013-95 — Richard N. Brogan v. Commissioner
    IRCCourt RulingsNov 26, 2013
    dividends of $2,294.88 over the life of the policy. Petitioner did not recall including the annual dividends in taxable income when they were paid to him, and there is no evidence that NY Life issued any Forms 1099 that would have prompted him to do so. In 2009 petitioner surrendered his policy to NY Life, and the com…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    have modified some parts of the 1968 regulations and would have left some parts of the 1968 regulations intact, the 1993 temporary regulations were a comprehensive set of regulations replacing the 1968 regulations in their ent irety. See T.D. 8552, 59 Fed. Reg. 34972 (July 8, 1994) (preamble to final 1994 regulations)…
  4. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015
    Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the IRM provision that addresses the Commissioner's ability to levy upon retirement accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330 hearing request and provided documents supporting this claim. Settlement Officer Degiovanni …
  5. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006
    …ht. Accordingly, aggregation was appropriate under those circumstances. Rev. Rul. 79-7, 1979-1 C.B. 294, holds that stock included in the decedent’s gross estate under the predecessor to section 2035(a) (requiring inclu sion in the gross estate of
  6. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
  7. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987★ strong match
    …Ill judge does not. Sec. 371(b) of the Judicial Code. Booth v. United States, supra. 28 U.S.C. sec. 294(b) (1982). Sec. 372(a) of the Judicial Code, unlike sec. 371(b) of the Judicial Code, does not specifically state that the judge retiring under such provision will continue to hold office. However, 28 U.S.C. sec. 294…
  8. 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 …
  9. 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…
  10. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …rrespond to the market value of gold bullion which backed the currency. See Perry v. United States, 294 U.S. 330 (1935); Nortz v. United States, 294 U.S. 317 (1935); Norman v. Baltimore & Ohio R.R. Co., 294 U.S. 240 (1935); Legal Tender Cases, 79 U.S. (12 Wall.) 457 (1870). As a second ground for rejecting the taxpayer…
  11. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …hin the coastal zone are governed by the Coastal Act. Sierra Club v. Cal. Coastal Comm’n , 111 P.3d 294, 303 (Cal. 2005) (holding that when a lot straddles the coastal zone boundary, the Coastal Commission retains jurisdiction over development for the portion of the lot within the coastal zone) . Petitioner provided no…
  12. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
  13. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022
    …rain marke ting and storage facility where petitioners stored the crops . CRAT I I distributed $ 69,294 of the proceeds to the charitable remaindermen and used the balance to purchase a nother SPIA from Symetra . Th is SPIA made annual annuity payments o f $124, 921 to petitioners in 2016 and 2017. Symetra again issued…
  14. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    …ence between the tax due and the estimated tax reported and paid. The addition to tax under section 294(d) (2) is properly determined on the basis of 80 percent of tax liability. To correct this error, a Rule 50 computation is necessary. Reviewed by the Court. Decision will be entered under Rule 50. SEC. 72. ANNUITIES:…
  15. 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…
  16. U.S. Tax Court — John R. Kirkpatrick v. Commissioner
    IRCCourt RulingsFeb 22, 2018
    …gross distributions of $116,489.39 from the first account. The other showed gross distributions of $294,665.64 from the second account. Each had a box checked to indicate that the taxable amount was not determined. Petitioner and Ms. Kirkpatrick filed a joint Federal income tax return for the 2013 taxable year, on whic…
  17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
  18. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984
    …w and Patricia J. Benbow 1978 $542.50 $130.20 Daniel W. Cass, Jr., and Barbara L. Cass 1978 $811.00 294.00 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…
  19. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    al right to decrease or altogether avoid such taxes by means which the law permits. Gregory v. Helvering, supra; Daniel D. Palmer, 62 T.C. 684 (1974). Respondent asserts that the result and reasoning of Rev. Rul. 68-303, 1968-1 C.B. 165, should control this case. In Rev. Rul. 68-303, a partnership entered into a contra…
  20. 76 FR 50883 — U.S. Customs and Border Protection
    IRCFinal Rules (FR)Aug 17, 2011
    …0.08 per copy. Based on this estimate, the cost savings on labor for printing is approximately $520,294 per year. Total Quantified Savings Exhibit 2 displays all of the cost savings that have been quantified for this analysis. ( printed page 50885) Exhibit 2—Total Savings From Reducing Paper Courtesy Notices in 2010 (U…