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21. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    rst articulated. 3 As a consequence, we set forth that analysis in order to bring into focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid" when the letter of credit was purchased on March 13, 1992. Statutory Framework The parties have stipula…
22. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …’s expert testimony on the basis of his failure to include certain publications as required by Rule 143(g)(1)(D). While we do not condone omission of these particular documents , w e find that the failure did not unduly prejudice respondent. Our sense at trial was that Dr. Reichert did not intend to violate t he spirit…
23. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
24. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
25. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    ate for respondent to change his position 6 months after the start of the trial and after all of petitioners’ witnesses had completed their testimony. On brief, respondent continues to argue section 131(c)(3)(B)(ii)(I) of R.A. 1978, as amended by section 252 of TEFRA; we continue to refuse to consider that argument in …
26. 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 …
27. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    to the additional tax under section 72(t) and distinguished Larotonda and Murillo on the ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is equally true of the distribution here. - 5 - To reflect the foregoing, An appropriate order of dismissal a…
28. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    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 …
29. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
30. 143 T.C. No. 5 — Parimal H. Shankar & Malti S. Trivedi v. Commissioner
    IRCCourt RulingsAug 26, 2014
    SA- t4dPd erns) 143 T.C. No. 5 UNITED STATES TAX COURT PARIMAL H. SHANKAR AND MALTI S. TRIVEDI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24414-12. Filed August 26, 2014. R disallowed Ps' deduction for contributions to their IRAs, which Ps claim are deductible because the limitations on ded…
31. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    …89 OPINION Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $ 143,327. The issue for decision is whether section 403(e)(3) of the Economic Recovery Tax Act of 1981, Pub. L. 97-34, 95 Stat. 305 (ERTA), precludes petitioner from qualifying for an unlimited marital deduction under sec…
32. T.C. Summary Opinion 2011-16 — Paulette A. & Matthew D. Malena v. Commissioner
    IRCCourt RulingsFeb 24, 2011
    …as let go from his job, and he defaulted on the loan, at which time the outstanding balance was $29,143. Petitioner and her husband filed a joint Federal income tax return for 2007. On the return, petitioner did not report the defaulted loan of $29,143 from her husband's 401(k). Petitioner attached to her joint return …
33. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    January 15, 2020. § 726.302(c)(2)(i) table $143 $146. § 726.302(c)(2)(i) table 285 290. § 726.302(c)(2)(i) table 428 436. § 726.302(c)(2)(i) table 569 579. § 726.302(c)(4) January 23, 2019 January 15, 2020. § 726.302(c)(4) $143 $146. § 726.302(c)(5) January 23, 2019 January 15, 2020. § 726.302(c)(5) $428 $436. § 726.30…
34. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
35. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …revenue agent’s report was attached to the SFR. Cabirac, 120 T.C. at 172. In Rader v. Commissioner, 143 T.C. 376, 382 (2014), aff ’ d in part, appeal dismissed in part , 616 F. App ’ x 391 (10th Cir. 2015) , we s ummarized the requirements of a section 6020(b) SFR : “ To constitute a section 6020(b) SFR, ‘the return mu…
36. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner. Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
37. 143 T.C. No. 11 — Dennis E. Bohner v. Commissioner
    IRCCourt RulingsSep 23, 2014
    143 T.C. No. 11 UNITED STATES TAX COURT DENNIS E. BOHNER, Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24166-12. September 23, 2014. While P worked for the Federal Government, he participated in the Civil Service Retirement System (CSRS). After P retired, he received a letter explaining that he…
38. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
39. T.C. Memo. 2014-143 — Keith Robertson v. Commissioner
    IRCCourt RulingsJul 21, 2014
    T.C. Memo. 2014-143 UNITED STATES TAX COURT KEITH ROBERTSON, Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20848-12. Filed July 21, 2014. Keith Robertson, pro se. Bradley C. Plovan, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge: The Internal Revenue Service (IRS or respon…
40. 143 T.C. No. 21 — Key Lime Investments, Inc. v. Commissioner
    IRCCourt RulingsNov 26, 2014
    143 T.C. No. 21 UNITED STATES TAX COURT RSW ENTERPRISES, INC., Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent KEY LIME INVESTMENTS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 14820-11R, 14821-11R. Filed November 26, 2014. Ps, domestic corporations, each established a retire…