IRCCourt RulingsFeb 9, 2023related by meaning
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsSep 2, 2021
…he business
relationship of the taxpayer to the persons entertained or using the property. See
sec. 274(d). With respect to the use of listed property, the taxpayer m ust establish
the am ount of business use and the am ount of total use. Sec. 1.274-5T(b)(6)(i),
Tem porary Incom e Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,…
IRCCourt RulingsApr 16, 2020
…axpayer whose inexactitude is of
his own making. See Cohan v. Commissioner, 39 F.2d at 544.
Section 274(d) imposes strict substantiation requirements for travel,
entertainment, gift, and listed property (including passenger automobiles)
expenses. Sanford v. Commissioner, 50 T.C. 823, 827 (1968), aff'd per curiam,
412 F…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCCourt RulingsSep 13, 2004
1.6001-1(a), (e), Income Tax Regs.
With respect to certain business expenses specified in
section 274(d), however, more stringent substantiation
- 9 - requirements apply. Section 274(d) disallows deductions for
traveling expenses, gifts, and meals and entertainment, as well
as for listed property, unless the taxpayer s…
IRCCourt RulingsJan 29, 2019
…ver, is superseded--that is, estimates are not
permitted--for certain expenses specified in section 274, such as traveling
expenses (including meals and lodging while away from home), entertainment
expenses, and "listed property" (including passenger automobile) expenses. Secs.
- 21 -
274(d), 280F(d)(4)(A)(i); sec. 1.2…
IRCCourt RulingsJun 4, 2014related by meaning
ation because R
proceeded against the target taxpayers using information W provided
before the effective date of I.R.C. sec. 7623(b), Dec. 20, 2006. W opposes R's motion on the grounds that W provided information to
the Government both before and after the effective date of I.R.C. sec.
7623(b).
Held: The Court has juri…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
IRCCourt RulingsOct 28, 1997
…er "whose inexactitude is of his own making."
Id.
at 544. An exception to the Cohan
rule is section 274(d),
which requires strict substantiation of certain expenses,
including those paid or incurred with respect to certain listed
property. Sec. 274(d). Listed property includes automobiles.
Sec. 280F(d)(4). Section 274(…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
IRCCourt RulingsJun 12, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
T.C. Memo. 1996-272
UNITED STATES TAX COURT
TOMMY L. AND PATRICIA A. HOBSON, Petitioners v
. COMMISSIONER OF
INTERNAL R…
IRCCourt RulingsMar 7, 2019
… 337 (1995). And for depreciation
deductions on any "listed property," a taxpayer must meet section 274(d)'s
heightened substantiation requirements. See secs. 274(d)(4) (2008), 280F(d)(4);
see also, e.g., WSK & Sons, Inc. v. Commissioner, T.C. Memo. 2015-204, at *12-
*13 (outlining section 274(d) requirements for passe…
T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua… IRCTreasury DecisionsMar 7, 2016related by meaning
or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security.
T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
IRCCourt RulingsMar 4, 1999
…4 -
When National Western terminated petitioner wife’s policy,
her outstanding loan balance was $73,274.49. National Western
issued petitioner wife a Form 1099-R, reflecting a taxable gain
of $23,274.49, which the company computed as the outstanding loan
balance of $73,274.49, less her investment in the contract of
$50…
T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. IRCTreasury DecisionsSep 18, 2006related by meaning
INCOME TAX
Notice 2006-76 Notice 2006-76
This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether i…
IRCCourt RulingsNov 21, 2023
…ave
not substantiated th ese reported expense s .
The strict substantiation requirements of section 274(d) apply to
travel expenses . Under section 274(d), the taxpayer generally must
substantiate either by adequate records or by sufficient evidence
corroborating the taxpayer’ s own statement (1) the amount of the
expe…
IRCCourt RulingsAug 25, 1997related by meaning
motion for costs
was filed out of time and should be "dismissed" for that reason.
We reject respondent's contention and do not consider it further.
12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA),
Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is
generally applicable to proceedings commenced after …
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
24 T.C. 460 — Northwest Automatic Products Corp. v. United States IRCCourt RulingsJun 23, 1955related by meaning
h respect to this matter is hereby set for_ at_if that time is not convenient, kindly advise us promptly in order that a continuance may- be arranged. This notice, sent by registered mail, constitutes commencement of the renegotiation proceedings in conformity with the provisions of subsection (c) (1) of the Renegotiat…