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87 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred. EMPLOYEE PLANS T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
  2. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …2(a) TORCH, docket No. 1480-10 2002 $99,391 $19,878 2003 526,695 105,399 2004 701 104 2005 18,916 3,783 Additions to tax Petitioner TYE Dec. 31 Deficiency Sec. 6651(a)(1) and (2) TORCH, docket No. 1448-10 2003 $44,711 $10,060 $11,178 2004 91,128 20,504 22,326 OPINION I. Burden of Proof The Commissioner's determination …
  3. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
  4. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …otal gross receipts of $109,926, total expenses of $37,280, and business use of home expenses of $6,783 for his "financial journalist corporate relations consultant" (consultant) business. As a self-employed individual, petitioner contributed to an SEP plan on the basis of his consultant earnings. Petitioner reported g…
  5. 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…
  6. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024
    …e . In connection with this increase to petitioners’ gross income, t he 2015 NOD also treated $25 , 783 of the SSE Tier 1 and Social Security benefits reported by the RRB and the SSA as taxable . B. 2016 In the 2016 NOD , respondent increased petitioners’ gross income from their SSE Tier 1 and Social Security benefits …
  7. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  8. 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…
  9. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020
    …Cir. 1984), affg T.C. Memo 1984-124; Burke Mountain Acad., Inc. v. United States, 715 F.2d 779, 782-783 (2d Cir. 1983). - 8 - II. Application of Section 72(t) Having set out the relevant framework that governs our analysis, we turn
  10. T.C. Memo. 1996-354 — Brent Allan Pulliam v. Commissioner
    IRCCourt RulingsAug 1, 1996
    …e, e.g., Estate of Cowser v. Commissioner , 736 F.2d 1168, 1171-1174 (7th Cir. 1984), affg. 80 T.C. 783, 787-788 (1983). In view of the foregoing, the Court holds that petitioner is liable for the 10-percent additional tax imposed by section 72(t). While the Court sympathizes with petitioner's financial situation, the …
  11. 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 …
  12. T.C. Summary Opinion 2018-16 — Albert Anthony Oliver v. Commissioner
    IRCCourt RulingsApr 3, 2018
    …ations. See Estate of Cowser v. Commissioner, 736 F.2d 1168, 11711174 (7th Cir. 1984), af[g 80 T.C. 783 (1983); see also Commissioner v. McCoy, 484 U.S. 3, 7 (1987); Woods v. Commissioner, 92 T.C. 776, 784-787 (1989); Hays Corp. v. Commissioner, 40 T.C. 436, 442-443 (1963), af[d, 331 F.2d 422 (7th Cir. 1964). We may no…
  13. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
  14. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012
    …d gross income reported on petitioners' return was $143,267. They underreported interest income by $783, rents and royalties by $670, Social Security benefits by $3,215, and dividends by $20,220. The tax reported on the return was $9,292. During 2007 petitioners received a total of $142,552 from their various
  15. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment. SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
  16. T.C. Summary Opinion 2005-78 — Hossam Helmy El-Bibany & Salma Hassan Kandil v. Commissioner
    IRCCourt RulingsJun 8, 2005
    …ten. See Estate of Cowser v. Commissioner , 736 F.2d 1168, 1171-1174 (7th Cir. 1984), affg. 80 T.C. 783 (1983). Accordingly, we conclude that petitioners are
  17. U.S. Tax Court — James Thomas & Susan Jane Colegrove v. Commissioner
    IRCCourt RulingsApr 13, 2010
    …ee Estate of Cowser v . Commissioner , 736 F .2d 1168, 1171-1174 (7th Cir . 1984), affg . 80 T .C . 783 (1983), and we may not rewrite the law because we may "deem its effects susceptible of improvement" ., Commissioner v . Lundy , 516 U .S . 235, 252 (1996) (quoting Badaraccov . Commissioner , 464 U .S . 386, 398 (198…
  18. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    IRCCourt RulingsNov 21, 2007
    …08 .94 8,427 .4 1 1994 66 .0084 15,698 .12 1,725 .72 17,423 .8 4 1995 108 .1071 46,776 .86 6 .29 46,783 .1 5 1996 144 .5164 108,732 .69 30 .90 108,763 .5 9 1996 110,116 .148 0 1997 10,323 .9064 304,555 .24 10 .31 304,565 .5 5 'Number of shares restated to reflect a 70-to-1 stock split . After petitioner left J .D . Edw…
  19. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
  20. T.C. Summary Opinion 2006-177 — Richard D. Smart v. Commissioner
    IRCCourt RulingsOct 25, 2006
    …ee Estate of Cowser v . Commissioner , 736 F .2d 1168, 1171-1174 (7th Cir . 1984), affg . 80 T .C . 783 (1983), and we may not rewrite the law because we may "'deem its effects susceptible of improvement"', Commissioner v . Lundy , 516 U .S . 235, 252 (1996) (quoting Badaracco v . Commissioner , 464 U .S . 386, 398 (19…