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85 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …ur analysis, see Jacobs, 1993 WL 495594, at *2-*3 (citing Spicer Accounting, Inc. v. United States, 918 F.2d 90, 92 (9th Cir. 1990)); £ sec. 31.3121(d)-1(a)(3), Employment Tax Regs. Indeed, the large difference between reported "wages" and "director fees" in this case makes us all the more skeptical about the true natu…
  2. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  3. T.C. Memo. 2022-3 — John M. Larson v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    … loss from Morley of $8,515,404 relating to his pro rata share of Morley’s reported loss of $26,887,918. In the notice of deficiency, respondent did not make a separate negative
  4. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    … at 1011 (quoting International Tel. & Tel. Corp. v. General Tel. & Elec. Corp. , 518 F.2d 913, 917-918 (9th Cir. 1975)). In reaching our conclusion, we followed the Supreme Court's approach in United States v. American Trucking Associations , 310 U.S. 534, 60 S.Ct. 1059, 84 L.Ed. 1345 (1940). There the Court noted tha…
  5. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  6. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …s. Frank Lyon Co. v. United States , 435 U.S. 561, 580 (1978); James v. Commissioner , 87 T.C. 905, 918 (1986), affd. 899 F.2d 905 (10th Cir. 1990). We agree with respondent, however, that the payments of the processing fees by Dura-Craft to Northwest were shams. Dura-Craft is a subchapter C corporation, and Northwest …
  7. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    470 in petitioner's deductions, a $144 decrease in petitioner's withholding credits, and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent Spolse Relief, seeking equitable relief from liability under the provisions of section 66(c). Respondent determ…
  8. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …6 and $22,476.41, respectively, and an enhanced accuracy-related penalty under section 6662A of $63,918.33. Also on June 9, 2011, respondent issued to petitioner a notice of deficiency for 2005 determining a total deficiency in Federal income and excise tax of $150,869, additions to tax under section 6651(a)(1) and (2)…
  9. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …Lyle B. Press, for respondent. THORNTON, Judge: The Internal Revenue Service (IRS) determined a $37,918 deficiency in petitioners' 2011 Federal income tax. The issues for decision are: (1) whether petitioners should receive a hardship waiver under - 3 - section 402(c)(3)(B) with respect to pension distributions that Mr…
  10. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    s, earnings, and reasonable charges) pursuant tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not : rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant to Rev. Proc . 2005-25, lsupra. Held, further, P must include in his gross income the excess contributiorls pursuan…
  11. 39 T.C. 1055 — Cohen v. Commissioner
    IRCCourt RulingsMar 27, 1963
    …_ 768.97 11_ __ 787.82 12_ __ 807.35 13_ __ 827.61 14_ __ 848.70 15_ __ 870.71 16_ __ 893.76 17_ __ 918.01 18_ __ 943.64 19_ __ 970.87 20_ 1, 000. 00 With respect to the payment of dividends the policy provided: Dividends
  12. T.C. Memo. 1998-388 — Robert B. Keenan v. Commissioner
    IRCCourt RulingsNov 2, 1998
    …result of the sale or disposition, including a sale in foreclosure. Chilingirian v . Commissioner , 918 F.2d 1251 (6th Cir. 1990), affg. T.C. Memo. 1986463. Section 1221(2) provides that real property used in a trade or business is not a capital asset (and therefore a loss from the
  13. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    … for a period of about 5 years); cf. Jerome Mirza & Associates, Ltd. v. United States, 692 F. Supp. 918 (C.D. Ill. 1988), affd. 882 F.2d 229 (7th Cir. 1989) (reasonableness of actuarial assumptions reviewed where 73 percent of pension benefit obligation was funded in first year of plan).
  14. T.C. Memo. 2001-146 — Michael T. Chappell v. Commissioner
    IRCCourt RulingsJun 20, 2001
    …al Bank account. He paid $3,258.33 in 1994 and $2,235.36 in 1995. The Lower Wetumpka Road house has 918 square feet and contains four rooms and a kitchen and bathroom. Petitioner used the large room in the front of the house as a waiting room during tax filing season. It was also used by the Freedom Quilting Bee, a 150…
  15. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
  16. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    alty in question has its roots in subtitle C of the Internal Revenue Code (Employment Taxes), a subtitle which falls outside the Court’s jurisdiction. Petitioners failed to file a timely objection to respondent’s motion, and on February 22, 1980, an order granting the motion was entered. Subsequently, on March 21, 1980…
  17. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    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…
  18. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …,607 Per-Entity 331 331 Total: Total Cost 164,098,348 3,061,442 34,613,730 66,284 Per-Entity Cost 1,918 3,314 132,457 3,314 SBA: Threshold (in $ millions) 15.0 45.5 47.0 47.0 Per-Entity Cost as a Percentage of SBA Threshold 0.013% 0.007% 0.282% 0.007% In response to comments, the Department has also conducted an analys…
  19. T.C. Memo. 2009-187 — Eugene & Glenda Dollander v. Commissioner
    IRCCourt RulingsAug 19, 2009
    …NIO N JACOBS, Judge : Respondent determined for 2005 a deficiency in petitioners' income tax of $16,918 and an accuracy-relate d ,penalty of $3,384 . After concessions by petitioners, the issues before the Court are : (1) Whether petitioners are liable for the 10-percent additional tax under section 72(t) with respect …
  20. U.S. Tax Court — Donald A. Hackenberg v. Commissioner
    IRCCourt RulingsSep 9, 2010
    …on or 14 - 7 - ownership of the property .is being changed ." Bolton v . MacDonald , 794 P .2d 911, 918 (Cal . 1990) (express declaration creating a joint tenancy must declare interest being transferred "to be a joint tenancy") . .- Although the arrangement contemplated by the addendum was already in . effect, the adde…