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21. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…
22. 51 T.C. 651 — Jones v. Commissioner
    IRCCourt RulingsJan 27, 1969
    …ofit-sharing, stock bonus, and similar plans. See H. Rept. No. 378, 87th Cong., 1st Sess., pp. 1-5 (1961); S. Rept. No. 992, 87th Cong., 1st Sess., pp. 1-9 (1961); Hearings before the Senate Finance Committee on HR. 10,87th Cong., 1st Sess., p. 20, et seq. (1961). Compare H.R. 10, 86th Cong., 1st Sess. (Senate referred…
23. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
24. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971
    1. In 1961 Harold and Caroline Smith sold their American Gas stock to Union Oil. The sale price finally agreed upon was $1,786,994.75, of which 459,812.13 was paid in 1961 and the balance was to be paid in annual installments over a 5-year period. On their 1961 joint Federal income tax return, the Smiths properly elect…
25. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
26. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    ed do not apply to requests for any documents to the extent § 6104 applies. Statement identifying information to be deleted from public inspection .04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
27. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    …reply brief includes 4-½ pages of objections to respondent's proposed findings of fact. Id . I. The Memorandum Opinion In T.C. Memo. 1995-492, filed October 11, 1995, the Court decided the present case. In our memorandum opinion, we rejected petitioners' argument that petitioner's Transfer Refund had not been received …
28. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
29. T.C. Memo. 2025-1 — Matthew D. Hutcheson & Annette Hutcheson v. Commissioner
    IRCCourt RulingsJan 2, 2025
    …See Charley v. Commissioner, 91 F.3d 72, 73 – 74 (9th Cir. 1996), aff’g in part, rev’g in part T.C. Memo. 1993-558. It is well established that when taxpayer s misappropriate money for their personal benefit , th e money is gross income under section 61(a). See James v. United States, 366 U.S. 213, 219 –2 0 (1961) . Mi…
30. 95 T.C. 415; 95 T.C. No. 30 — Albertson's, Inc. v. Commissioner
    IRCCourt RulingsOct 9, 1990related by meaning
    o. v. Commissioner, 30 T.C. 10, 22-23 (1958), affd. 267 F.2d 853 (7th Cir. 1959); Times Publishing Co. v. Commissioner, 13 T.C. 329, 335 (1949), affd. per curiam 184 F.2d 376 (3d Cir. 1950). Section 23(p) was reenacted as section 404 in the 1954 Code in essentially the same form. Don E. Williams Co. v. Commissioner, 42…
31. T.C. Memo. 2017-76 — Christopher S. Harrell, Sr. & Ingrid T. Harrell v. Commissioner
    IRCCourt RulingsMay 8, 2017
    … expenses. Funeral expenses are clearly personal or family expenses. See Beck v. Commissioner, T.C. Memo. 2001-270, 2001 Tax Ct. Memo LEXIS 309, at *43 (holding that income tax deduction claimed for wife's funeral expenses was a nondeductible personal expense); Carr v. Commissioner, T.C. Memo. 1979-400, 1979 Tax Ct. Me…
32. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
33. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …), affd. without published opinion 578 F.2d 1383 (8th 042 Cir. 1978); Bartley v. Commissioner, T.C.·Memo. 1998-322; Ruben v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner, T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696; Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v. Commissione…
34. 45 T.C. 168 — Lilly v. Commissioner
    IRCCourt RulingsNov 26, 1965
    …ontributions to the widows’ fund in the amount of $430.56. During each of the years 1959, 1960, and 1961, petitioner received an amount of $1,024.92 from the widows’ fund. Petitioner did not report any amount received from the widows’ fund as income in any of her returns for the years in question. All the returns were …
35. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
36. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983
    …ies); Moore v. Commissioner, 71 T.C. 533 (1979) (retail grocery store); Black v. Commissioner, T.C. Memo. 1983-245 (sales of developed real estate); Pilkington v. Commissioner, T.C. Memo. 1983-111 (operation of lounge); Smith v. Commissioner, T.C. Memo. 1983-93 (paint contracting business); Nelson v. Commissioner, T.C.…
37. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
38. Treas. Reg. § 1.404(a)-2(e) — Information to be furnished by employer claiming deductions; taxable years ending before December 31, 1971.
    IRCRegulationsMar 14, 2019
    … section 404 or qualification under section 401. For taxable years ending on or before December 31, 1961, the district director may waive the filing of such information required by this section which he finds unnecessary in a particular case. For taxable years ending after December 31, 1961, the Commissioner may waive …
39. 91 FR 55462 — Federal Independent Dispute Resolution Operations; Correction
    IRCFinal Rules (FR)Aug 28, 2026related by meaning
    on, Publications and Regulations, Associate Chief Counsel, (Procedure and Administration) Department of the Treasury. In concurrence: Kurt D. Dykstra, General Counsel, Office of Personnel Management. [FR Doc. 2026-17622 Filed 8-27-26; 8:45 am] BILLING CODE 6325-63-P; 4831-GV-P; 4510-29-P; 4169-69-P
40. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…