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21. Treas. Reg. § 1.72-11(c)(2) — Amounts not received as annuity payments.
    IRCRegulationsJan 19, 2017
    …ubtract amount excludable during five years A received payments (19.6 percent of $4,500 [$900 × 5]) 882 Remainder of aggregate of premiums or other consideration paid excludable from gross income of B under section 72(e) 2,718 As a result of the above computation, the number of payments to B which will exhaust the rema…
22. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014related by meaning
    her authority that would distinguish the Martin cases from the issue presented before the Court. Accordingly, petitioners have not met their burden of proving that the weight of the authorities supporting the treatment of the IRA - 25 - [*25] distributions is substantial in relation to the weight of the authorities sup…
23. Treas. Reg. § 1.404(a)-11 — Trusts created or organized outside the United States; application of section 404(a)(4).
    IRCRegulationsMay 18, 2016
    …ect to the conditions and limitations of section 404(a) and to the extent allowed by section 873 or 882(c).
24. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024★ strong match
    …so Swallows Holding, Ltd. v. Commissioner, 515 F.3d 162, 171 (3d Cir. 2008) (construing the section 882(c)(2) requirement that certain returns be filed “in the manner prescribed in subtitle F” as ambiguous with respect to whether the term “manner” included an element of timeliness), vacating and remanding 126 T.C. 96 (…
25. Treas. Reg. § 1.406-1(e)(1)(ii) — Treatment of certain employees of foreign subsidiaries as employees of the domestic corporation.
    IRCRegulationsMay 18, 2016
    …ted with the conduct of a trade or business within the United States (within the meaning of section 882 and the regulations thereunder) an amount which is allocable and apportionable to such gross income under the rules of § 1.861-8 and which in no event may exceed the amount which (but for subdivision (i) of this subp…
26. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue. (b) Retroactivity of R…
27. Treas. Reg. § 1.1563-1(b)(2)(ii) — Definition of controlled group of corporations and component members and related concepts.
    IRCRegulationsDec 30, 2024
    …or such taxable year; (b)(2)(ii)(B) (B) A foreign corporation not subject to taxation under section 882(a) for the taxable year; (b)(2)(ii)(C) (C) An S corporation (as defined in section 1361) for purposes of any tax benefit item described in section 1561(a) to which it is not subject; (b)(2)(ii)(D) (D) A franchised co…
28. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
29. U.S. Tax Court — Cynthia M. Martinez v. Commissioner
    IRCCourt RulingsDec 29, 2008
    … 1995, 1998, and 1999, which as of April 17, 2007, had remaining balances due of $7,038, $1,914, $4,882, and $5,965, respectively, for a total of $19,799 . The issue for decision is whether petitioner is entitled t o innocent spouse relief for any or all of the years at issue . Background Some of the facts have been st…
30. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …able income 2003 $1,643,523 $1,550,807 $92,716 2004 1,488,793 1,390,853 97,940 2005 1,688,916 1,693,882 (4,966) 2006 1,903,914 1,884,065 14,883¹4 ¹³ BAI's fiscal year ends June 30. Therefore, all references to BAI's tax years at issue refer to the calendar years in which BAI's fiscal years began. For example reference …
31. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
32. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015related by meaning
    e parties agree that there is no genuine dispute as to any material fact. After reviewing the pleadings and the comprehensive stipulation of facts and the attached exhibits, we conclude that a decision may be rendered as a matter of law. - 13 - [*13] II. Statutory Framework A. DISCs7 A DISC provides a mechanism for def…
33. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …to $175 million showed the top compensation of any CEO to be $703,530 for 1988, $779,555 for 1989, $882,680 for 1990, and $838,970 for 1991. The compensation shown in the ECS survey was total cash compensation, including salary, bonuses, and cash fringe benefits. The following schedule shows information taken from prox…
34. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …ttling Co. v. Commissioner , 50 T.C. 391, 398 (1968); New York Post Corp. v. Commissioner , 40 T.C. 882, 888 (1963); and Harry A. Wellons, Jr., M.D., S.C. v. Commissioner , T.C. Memo. 1992-704. We disagree. The plan at issue in each of the cases cited by respondent is distinguishable from the Prime Plan. Such is also t…
35. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
36. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …64 (10th Cir. 1975); Noble v. Commissioner , 368 F.2d at 442; Sachs v. Commissioner , 277 F.2d 879, 882 (8th Cir. 1960), affg. 32 T.C. 815 (1959); Yelencsics v. Commissioner , 74 T.C. 1513, 1529 (1980); Magnon v. Commissioner , 73 T.C. 980, 997 (1980). Petitioners seek to distinguish the facts in many of the above case…
37. 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 …
38. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012
    …ot grounds - 8 - [*8] for disqualification or recusal. See United States v. Conforte, 624 F.2d 869, 882 (9th Cir. 1980); United States v. Carroll, 567 F.2d 955, 958 (10th Cir. 1977); United States v. Haldeman, 559 F.2d 31, 136 (D.C. Cir. 1976); United States v. Mine, 466 F.2d 1000, 1003-1004 (7th Cir. 1972). Because we…
39. 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…
40. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    "notified" of that ownership, (2) if respondent was so "notified", when respondent was "notified", and (3) whether the date on which respondent - 16 - was so "notified" was later than the ownership that gives rise to the excise tax under section 4979A(a). Section 4979A(e)(2)(D) does not define the term "notified", and …