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…
IRCCourt RulingsSep 23, 2014
… of statutory
construction tell us that the omission is intentional. Rand v. Commissioner, 141
T.C. 376, 390-391 (2013). And we should interpret the provision consistent with
the omission; we do not add a rule to the statute that Congress did not itself
include.
The strongest statutory authority the opinion of the Cour…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsMay 28, 1962related by meaning
ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
IRCCourt RulingsAug 28, 2008
…ge : Respondent determined an $11,846 .40
deficiency in petitioner ' s income tax for 2003 and a $2,376 .99
addition to tax for failure to file a return timely under sectio n
6651(a)(1),1 a $2,376 .99 addition to tax for failure to pay tax
timely under section 6651(a)(2), and a $272- .75 . addition to tax
for failure t…
IRCCourt RulingsAug 24, 1995related by meaning
drawn therefrom), but that, if such order were not a QDRO, petitioner’s ex-husband and not petitioner would be taxable in respect of the distribution. As will subsequently become apparent, such all-or-nothing treatment will not necessarily flow from our decision herein. Indeed, the road to decision herein is a rocky on…
IRCCourt RulingsMar 5, 2018
…over the property taxed--the actual benefit for
which the tax is paid." Corliss v. Bowers, 281 U.S. 376, 378 (1930).
33(...continued)
income taxation", id. at 434, a principle first enunciated in such cases as Lucas v.
E_ad, 281 U.S. 111 (1930), and Corliss v. Bowers, 281 U.S. 376, 378 (1930). The
assignment of income …
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…ie, Evan Xu, & Ziyad Al-Aly,
Risks of Mental Health Outcomes in People with Covid-19: Cohort Study,
376 The BMJ (2022),
https://www.bmj.com/content/376/bmj-2021-068993.
Back to Citation
219.
Mario G. Mazza, Mariagrazia Palladini, Rebecca De Lorenzo, Beatrice Bravi, Sara Poletti, Roberto Furlan, Fabio Ciceri, Patriz…
IRCCourt RulingsAug 6, 1996related by meaning
by section 404(a)(6), and are therefore not deductible
in that year.
To reflect the foregoing and issues previously resolved,
Decision will be entered under Rule 155
.
88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
… and Ziyad Al-Aly. “Risks of Mental Health Outcomes in People with Covid-19: Cohort Study.”
The BMJ
376 (2022), available at https://www.bmj.com/content/376/bmj-2021-068993.
Back to Citation
223.
Mazza, Mario Gennaro, Mariagrazia Palladini, Rebecca De Lorenzo, Beatrice Bravi, Sara Poletti, Roberto Furlan, Fabio Cic…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
IRCCourt RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsNov 21, 2023
… penalty or increase in the amount of a penalty asserted in his
answer. See Rader v. Commissioner , 143 T.C. 376, 389 ( 2014), aff’d in
part, appeal dismissed in part , 616 F. App ’ x 391 (10th Cir. 2015) ; see also
RERI Holdings I, LLC v. Commissioner , 149 T.C. 1, 38 – 39 (2017), aff ’ d
sub nom. Blau v. Commissioner…
IRCCourt RulingsJan 22, 2025
…, and the return form and any attachments must purport to be a ‘ return ’ .” Rader v. Commissioner, 143
T.C. 376, 382 (2014) ( quoting Spurlock v. Commissioner, T.C. Memo.
2003- 124, slip op. at 27) , aff’d in part , appeal dismissed in part , 616
F. App’x 391 (10th Cir. 2015); see also A shford v. Commissioner , T.C.
…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
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., …
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
contractor or subcontractor” within the meaning of section 403 (a) (4) (D), as to all contracts whether executed by itself or by the Georgia company. The respondent contends that the separate entities may not be ignored. He states that under the Mississippi company’s method of operation, that is, at cost, that company…
IRCCourt RulingsJun 30, 1982related by meaning
ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
IRCCourt RulingsSep 29, 2022
…documents is sufficient to constitute a valid SFR under section 6020(b). See Rader v.
Commissioner, 143 T.C. 376, 382 (2014) (citing Gleason v. Commissioner, T.C. Memo.
2011- 154, 2011 WL 2600917, at *12), aff’d in part , 616 F. App ’ x 391 (10th Cir. 2015).
10
The section 6654 addition to tax is calculated with refere…