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41. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003related by meaning
    ng this amount. Subsequently, J.D. merged into Clarkston pursuant to section 368, and filed a final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the final return year of J.D. eliminated by book entry as a result of the merger. - 5 - Discussion Respondent’s …
42. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008
    … could have been devoted to resolving bona fide claims of other taxpayers . See Cook v . Spillman , 806 F .2d 948 (9th Cir . 1986) . Petitioner's insistence on making frivolous tax-defier arguments indicates an unwillingness to respect the tax laws of the United States . Accordingly, we shall require petitioner to pay …
43. 49 T.C. 174 — Armanco Productions, Inc. v. Commissioner
    IRCCourt RulingsDec 8, 1967related by meaning
    t-sharing trust. Our conclusion makes it unnecessary to consider respondent’s alternative argument that the deduction should be limited to $10,346.69. Section 401(a) and the regulations pursuant thereto require that the plan not discriminate in favor of employees who are officers, shareholders, or highly compensated em…
44. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    …ely on ignorance of the law for relief from liability. Mitchell v. Commissioner , 292 F.3d 800, 803-806 (D.C. Cir. 2002), affg. T.C. Memo. 2000-332. Regardless of whether the taxpayer “possesses knowledge of the tax consequences of the item at issue, * * *[he] is considered as a matter of law to have reason to know of …
45. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    gift tax As Mrs. Cadwell would be the' hypotlietical' donorain' thé scehario posited by petitioner, we conclude that section 2523^ does not" apply. - Petiltionery may have meantato ácite as support for his contention sec tion 102 (a) , which exc ludes f rom- gros s income the value of property acquired by Égift Howeve…
46. DOL Office of Administrative Law Judges — USDOL, EMPLOYEE BENEFITS SECURITY ADMINISTRATION v. PLAN ADMINISTRATOR, WHITE MOUNTAIN APACHE TRIBE RETIREMENT SAVINGS AND 401(K) PROFIT SHARING PLAN ANNUAL RE…
    ERISACourt RulingsNov 30, 2016
    …ernmental plan” in ERISA to include cer tain Indian Tribal government plans. Pub. L. No. 109-208, § 806(a)(2)(A), 120 Stat. 780, 1051 (Aug. 17, 2006). To be eligible for treatment as a governmental plan and exempt from ERISA reporting
47. T.C. Summary Opinion 2003-161 — Martin Edward Caulfield v. Commissioner
    IRCCourt RulingsNov 7, 2003
    …thout regard to the amount of tax withheld on a taxpayer's income. Redcay v. Commissioner , 12 T.C. 806, 809-810 (1949); sec. 301.6211-1(b), Proced. & Admin. Regs. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.
48. U.S. Tax Court — Michael K. Billups v. Commissioner
    IRCCourt RulingsJun 1, 2009related by meaning
    account of the employee's disability ; (4) as part of a serie s e for life ; (5) to a employee after separation from service after attainment of ag A substantially equal periodic payments m 55 ; (6) as dividends paid with, respect to corporate stoc k described in section 404(k) ; (7) to an employee for medica l or (8)…
49. T.C. Memo. 2003-294 — Randolph S. Simpson, I v. Commissioner
    IRCCourt RulingsOct 21, 2003
    … claimed the standard deduction. On line 16a, Total pensions and annuities, petitioner reported $42,806 and reported the entire amount as taxable on line 16b, Taxable amount. On line 30a, Alimony paid, petitioner claimed an adjustment to income of $17,900 for alimony paid. No other income or adjustments were - 5 - repo…
50. T.C. Memo. 2017-132 — Jack Howard Taylor v. Commissioner
    IRCCourt RulingsJul 5, 2017
    … was submitted fully stipulated for decision without trial. M Rule 122.¹ Respondent determined a $3,806 deficiency in petitioner's Federal income tax for tax year 2012. Petitioner has conceded all adjustments, save for the inclusion in taxable income of an additional $32,505 in benefits paid by the Local Governmental E…
51. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011related by meaning
    7491(a) (2) have been met. Because petitioner is asserting a position that is contrary to the position taken on his 2006 return, he must offer cogent proof that his return position was incorrect. See Mendes v. 7The term "Secretary" means "the Secretary of the Treasury or his delegate", sec. 7701(a)-(11) (B), and the t…
52. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    n 6662(a) and (b)(1) and (2), a taxpayer may be liable for a penalty of20% 5 Over petitioner's objection respondent introduced a literal transcript of account for petitioner's 2010 tax year. The literal transcript contains no reference to any SFRs. Even if it did, the literal transcript does not establish that the requ…
53. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022related by meaning
    at trial that he had filed a return for 2012 showing tax due. Although his 2013 account transcript r eflects a withholding credit of $320 , petitioner has neither argued nor shown that his 2013 withholding equaled or exceeded the amount of tax shown on his 2012 return. As for 2014, petitioner’s required annual payment …
54. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997
    … payment is made and not the source of the particular taxpayer's injury. Smelley v. United States , 806 F. Supp. 932, 935 (N.D. Ala. 1992), affd. per curiam 3 F.3d 389 (11th Cir. 1993). Thus, if the statute does not qualify, the fact that the taxpayer's injury was in fact work related is irrelevant. Id. Eligibility for…
55. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974related by meaning
    ew principal place of work. Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217. SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
56. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    … of what is now section 482 was enacted in 1928. Revenue Act of 1928 , ch. 852, § 45, 45 Stat. 791, 806. Through it, Congress granted Treasury the authority to reallocate the reported income and deductions of related businesses “in order to prevent evasion of taxes or clearly to reflect the income of any such trades or…
57. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997
    … 31, 1982, and December 31, 1984, as follows: Trust Yearend Amount of Contribution Dec. 31, 1982 $4,806,000 Dec. 31, 1983 25,761,346 Dec. 31, 1984 27,424,715 Petitioner's 1985 VEBA Trust Contributions During November 1985, the VEBA Trust filed with respondent a Form 1128 to change its taxable year from a calendar year …
58. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    …ces electronically, resulting in roughly 665,458 fewer notices in the first year and on average 605,806 fewer in subsequent years being mailed. since the initial enrollment notice provides an opportunity for RCH/PSN to consolidate two notices into one. This reduction of notices being sent has an associated estimated co…
59. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989related by meaning
    e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
60. T.C. Memo. 1998-164 — Roland R. & Virginia A. Fox v. Commissioner
    IRCCourt RulingsMay 5, 1998
    …Sec. 6651(a)(1); United States v. Boyle , 469 U.S. 241, 245 (1985); Davis v. Commissioner , 81 T.C. 806, 820 (1983), affd. without published opinion 767 F.2d 931 (9th Cir. 1985). 2. Section 6662(a) Taxpayers are liable for a penalty under section 6662 equal to 20 percent of the part of the underpayment which is attribu…