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77 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016
    … Prorated 2003 property taxes $212.94 Earnest money deposit (cash) 60,000.00 Other cash payment 341,764.56 Promissory note to seller 200,000.00 Purchase price 601,977.50
  2. 31 T.C. 1182 — Finnie Co. v. United States
    IRCCourt RulingsMar 24, 1959
    …ate Nonrene-gotiable Total Sales.. Net profit... Percentage.. $527,637 $150,991 28.61* i $16,490 $4,764 28.8 $544,127 $155,755 28.6 $432,637 $55, 991 12.9 $16,490 $4,764 28.8 $449,127 $60,755 13.5 1 Of this amount $16,054 represented sales of salted peanuts to the corporation and its subsidiary. Petitioner’s invested c…
  3. Treas. Reg. § 1.417(a)(3)-1(e) — Required explanation of qualified joint and survivor annuity and qualified preretirement survivor annuity.
    IRCRegulationsSep 9, 2016
    …$900 per month for survivor annuity) Approximately the same value as the Life Annuity. Lump sum $74,764 Approximately 45 percent of the value of the Life Annuity. Age 60 Commencement Optional form Amount of distribution per $1,000 ofimmediate single life annuity Relative value Life Annuity $1,000 per month n/a. QJSA (J…
  4. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  5. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002
    … 4,152 Taxes 617 -0- 175 · -0Miscellaneous itemized 70 -0- 75 -0Other Sec. 72(t) additional tax -0- 764 -0- 2,566
  6. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
    IRCCourt RulingsAug 28, 1996related by meaning
    ented are contained in pleadings and other documents in the record, and are not controverted. We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's 1991 taxable year. If respondent was not entitled to do so, then the August notice would not be valid as…
  7. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    4 (1984); see United States v. Mead Corp., 533 U.S. 218 (2001). Although they may be entitled to deference under Skidmore v. Swift & Co., 323 U.S. 134 (1944), see United States v. Mead Corp., supra, we need not decide whether Notice 2004-8, supra, should be given Skidmore deference because the Transaction does not féll…
  8. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    e relaxed transfer pricing rules of section 925(a)(1) and (2) were used instead of the normal section 482 rules, then the lower the profit margin on a particular export transaction, the lower the effective marginal tax rate for that transaction (because as the profit margin decreased, the amount of taxable income assig…
  9. 70 T.C. 788 — 212 Corp. v. Commissioner
    IRCCourt RulingsAug 31, 1978related by meaning
    ioner for the purpose of computing its depreciation deductions. FINDINGS OF FACT Some of the facts have been stipulated, and those facts are so found. The petitioner in docket No. 8683-74 is 212 Corporation (212 Corp.), which had its principal place of business in Erie, Pa., at the time it filed its petition in this ca…
  10. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …1 31,348,486 47,539,329 3. Actuarial present value of future normal costs [1-2] 1 13,361,588 43,354,764 79,243,620 85,002,545 4. Actuarial present value of future service 4.81 6.63 7.26 7.19 5. Normal cost at beginning of year [3/4] 2,777,877 6,539,180 10,915,099 11,822,329 6. Maximum contribution 2 a. Paid at beginnin…
  11. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003related by meaning
    the service provider, the former did not pay the latter for its services within 2-1/2 months after the close of the respective calendar years in which the services were performed. 4 Nor have petitioners made the requisite showing to rebut the presumption that Clarkston’s arrangement with J.D. as to its services did not…
  12. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …-7,519 Fiduciary fees 53,836 63,293 22,994-0 - - 0 - Attorney, accountant 13,247 136,440 96,205 104,764 173,804 Other deductions 3,500-0-16 1,761 10,547 Other deductions: mgmt/admin fees-0 - - 0-173,550 79,263 128,000 Exemption 100 100 100 100 100 Taxable Income 164,781 199,276 (20,428) (22,898)(182,687) Total tax 46,1…
  13. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024
    …t 89 0 (treating a statute of limitations as a procedural rule); Anderson v. Unisys Corp. , 52 F.3d 764, 765 n.1 (8th Cir. 1995) 41 (“[W]e consider the limitations period a procedural rather than a substantive requirement, and have found that ‘ courts apply the procedure in effect when the case is before them. ’ ” (quo…
  14. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Either party may move for summary adjudication upon all or any part of the legal issues in controversy. Rule 121(a). Full or partial summary judgment is appropriate where the record shows that there is no genuine issue as to any material fact and that a decisi…
  15. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    e within the parameters spelled out in section 404(a)(6), may be deducted in the prior year, but only if they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
  16. 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 .
  17. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    IRCCourt RulingsNov 21, 2007
    …oner , 27 T .C . 1056, 1066 (1957) (and the cases cited thereon), revd . on other grounds 251 F .2d 764 (7th Cir . 1958) . This is particularly true in a case like this where the issue cannot be considered without surprise and prejudice to the other party . See Estate of Mandels v . Commissioner , 64 T .C . 61, 73 (197…
  18. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005
    …ce III , for respondent. MEMORANDUM OPINION WELLS, Judge : Respondent determined a deficiency of $2,764 in petitioner’s Federal income tax for 2001. The issue to be decided is whether petitioner’s 2001 gross income includes the amount of a check petitioner received but did not cash in 2001. All section references are t…
  19. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984related by meaning
    act represents reallocated forfeitures, the parties may be able to handle the matter under Rule 155, if that can be done without reopening the record. The Nov. 9,1977, letter stated the reasons for the proposed adverse determination as follows: The final adverse determination letter, dated Mar. 28, 1979, stated in pert…
  20. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …