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54 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 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)…
  3. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  4. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  5. 100 T.C. 521; 100 T.C. No. 34 — Karem v. Commissioner
    IRCCourt RulingsJun 14, 1993
    …ion plans covered by ERISA, after the REA amendments, were considered in Ablamis v. Roper, 937 F.2d 1450 (9th Cir. 1991). The issue in Ablamis was whether California community property laws, which might have allowed a wife who predeceases her husband to leave half of his current or future pension benefits to a third pa…
  6. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    oner , supra at 780. 11 See id. at 773. 12 See Eckel v. Commissioner , T.C. Memo. 1990-174. 13 See, e.g., In re Hatton , 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang , 164 F.3d 1029, 1033 (6th Cir. 1999). section 6653(a), 3 section 6662, 4 section 6013, 5 section 6033, 6 section 6651(f), 7 section 6511, 8 sect…
  7. 101 T.C. 489; 101 T.C. No. 32 — Powell v. Commissioner
    IRCCourt RulingsNov 29, 1993
    …a different result where community property laws apply. We likewise find Ablamis v. Roper, 937 F.2d 1450 (9th Cir. 1991), and Karem v. Commissioner, 100 T.C. 521 (1993), cited by the parties, distinguishable. Both of these cases held that the modifications of ERISA by section 414(p), see supra p. 491, preempted communi…
  8. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    ¹² The Commissioner here also doesn't seek to redetermine income tax, but only because the statute of limitations has run--he says if it hadn't, he'd redetermine the income tax too. We previously decided this was enough of a distinction from Hellweg to let these cases go forward on the excise-tax issue alone. Mazzei v…
  9. 31 T.C. 902 — Mansfield Journal Co. v. Commissioner
    IRCCourt RulingsJan 29, 1959
    … 390; McCue Bros. & Drummond, Inc., 19 T.C. 667, affd. 210 F. 2d 752; and Isadore Golonsky, 16 T.C. 1450, affd. 200 F. 2d 72. These cases, on their respective facts, are distinguishable from the instant case. It is held that the gains realized by petitioner in 1951 and 1952 from the transactions in question were not ca…
  10. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
  11. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
  12. IRCCourt RulingsAug 31, 1977related by meaning
    defects arising from innocent inadvertence.” See, however, sec. 401(b), which allows retroactive effect of amendments to the terms of employee plans. The stipulated facts are not clear on this point but indicate that the deduction for the contribution to the plans by Albets was not disallowed, presumably because respo…
  13. T.C. Memo. 1996-378 — Gaylord W. Greenlee v. Commissioner
    IRCCourt RulingsAug 15, 1996related by meaning
    c. Year 6651(a)(1) 1985 $ 813 1986 1,123 1987 1,403 1988 1,529 1989 1,581 1990 1,539 Then, in her reply brief, she conceded that the correct additions to tax are as stated in the text. The primary issue for decision is whether petitioner engaged in a prohibited transaction so as to be subject to the first-tier excise t…
  14. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013related by meaning
    ed CST, an entity owned by his IRA, to enter into a lease agreement with CDJ, an entity owned by both petitioners and their children in tax year 2006. The notice of deficiency also reflected respondent's determination that, for the year in which the prohibited transaction occurred petitioners are liable for the additio…
  15. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  16. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  17. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
  18. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  19. T.C. Memo. 2015-162 — Charles Dereck Adams & Melinda Elizabeth Adams v. Commissioner
    IRCCourt RulingsAug 17, 2015related by meaning
    n 72(t) applies. The only exception they have alleged, by way of partial offset to the additional tax, is the exception for "medical expenses." - 10 - [*10] Petitioners have the burden of proving that this exception applies. See El v. Commissioner, 144 T.C. __, __ (slip op. at 11-15) (March 12, 2015). Although the IRS …
  20. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…