167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…tate law. See Belk v.
Commissioner, 140 T.C. 1, 13 n.21 (2013) , supplemented by T . C. Memo.
2013- 154, aff’d , 774 F.3d 221 (4th Cir. 2014). In Alabama judicial review
of an unambiguous contract is limited to the four corners of the
document. See Lafayette Land Acquisitions II, LLC v. Walls, 385 So. 3d
519, 522– 23 (…
IRCCourt RulingsOct 9, 1997related by meaning
ent with the intent of
DEFRA, and because it permissibly fills a gap created by sections
419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is
not impermissibly broader than sections 419 and 419A and,
accordingly, we hold that it is valid. Chevron…
IRCCourt RulingsMar 31, 2008
… circumstances . Geftman v . Commissioner ,
T .C . Memo . 1996-447, revd . in part on other grounds 154 F .3d 61
(3d Cir . 1998)
. The ultimate question remains whether "there
[was] a genuine intention to create a debt, with a reasonable
IRCCourt RulingsDec 11, 2003related by meaning
he year at issue, and
all Rule references are to the Tax Court Rules of Practice and
- 4 -
1
Sec. 7491, which, under certain circumstances, shifts the burden of proof to the Commissioner, is inapplicable because the
examination in this case began before July 22, 1998, the
effective date of that section. See Internal Re…
IRCCourt RulingsJun 14, 2012related by meaning
ess doctrine, courts may invalidate laws if "'men of common
intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor
- - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945
F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra
addresses tran…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsOct 8, 2003
… F.3d 1435, 1439-1442 (Fed. Cir. 1996), and
Truck & Equip. Corp. v. Commissioner
, 98 T.C. 141, 145-154
(1992). We stress that the House Committee on Ways and Means, in
describing a 1984 amendment to sec. 404(b), stated that:
Generally, all compensation arrangements which defer
receipt of compensation by the employee o…
IRCPrivate Letter RulingsDec 20, 2013
…d States , 173 Ct. Cl. 139, 351 F.2d 619 (1965); and Estate of
S cofield v. Commissioner , 266 F.2d 154, 159 (6th Cir. 1959), revg. 25 T.C. 774 (1956).
CONCLUSION:
PLR - 113782-13 11
Taxpayer is allowed a loss under section 165 relating to the to the surrender of
BOLI Policies 1, 2, and 3, with the amount of such loss …
ERISACourt RulingsAug 14, 2026
…p’x at 152–53. He was “present for all of the negotiations up through the ’93 negotiations.” Id. at 154. Porter
affirmed, under oath, that during the 1993 negotiations, he
“believe[d] the state of the law was we couldn’t touch” the
healthcare benefits of a former employee who had retired
prior to the 1993 negotiations. As…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
IRCCourt RulingsNov 21, 2023
…new areas of technology. During the years in issue Mobile paid him a
yearly salary ranging between $154,000 and $159,000.
In addition to working for Mobile, petitioner husband owned and
operated a sole proprietorship from 2006 to 2014. Doing business as
“ K J Marketing ,” petitioner husband identified new markets for
c…
IRCCourt RulingsAug 31, 1978related by meaning
41), cert. denied 314 U.S. 621 (1941); see also sec. 1.170-l(c), Income Tax Regs.; sec. 20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs. The petitioners argue that the parties agreed upon a value of $225,000 for the properties and that this Court is bound to respect the value contractually agreed upon by …
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…
1993
1994
A. Investment return 6.6% 6.0% 5.7% 4.9%
B. Present value accrued benefits
a. Active $11,154,103 $30,515,975 $38,396,684 $61,044,923
b. Retired 23,798,600
33,006,450
38,374,995
42,599,819
c. Total 34,952,703 63,522,425 76,771,679 103,644,742
C. Value of assets (beginning of year)
a. VEBA --- 30,736,554 30,17…
IRCCourt RulingsSep 25, 2019related by meaning
w that there is a
genuine dispute for trial that he had reasonable cause for not paying the unpaid tax
on the 2013 return made for him by RA Landadio. C. Summary Judgment
Rule 121(b) provides that, in the absence of a genuine dispute as to any
material fact, and if a decision may be rendered as a matter of law, we must…
IRCCourt RulingsJul 31, 2000
…reon
equaled the interest rate earned on the policy). The Southland
policy’s accumulated value was $154,483 on December 28, 1994, its
surrender charge for that year was $68,800, and the interest
credited to the policy during that year approximated $5,046.96.
For 1994, a $3.2 million term insurance policy on the life of…
IRCCourt RulingsNov 14, 1996
… States
, 97 F.3d 1435 (Fed. Cir. 1996); Truck & Equipment
Corp. v. Commissioner
, 98 T.C. 141, 145-154 (1992). Second, we
recognize that it does not necessarily follow that funds have
been paid because they have been constructively received for
income tax purposes. See Gillis v. Commissioner
, 63 T.C. 11, 17
(1974). T…
IRCCourt RulingsJan 3, 2011related by meaning
,000," and ( ) the cost of
term life insurance on petitioner's life for 2004 of $13,510.
Petitifoner timely filed a petition in this Court.
Discussion Rule 121(a) allows a party to move "for a summary
adjudication in the moving party's favor upon all or any part of
the 1 gal issues in controv rsy." Rule 121(b) directs …
IRCCourt RulingsFeb 25, 2016
…ed. See Cabirac v.
Commissioner, 120 T.C. 163, 170 (2003); Gleason v. Commissioner, T.C. Memo.
2011-154. A return for section 6020(b) purposes must contain sufficient
information from which to compute the taxpayer's tax liability. Spurlock v.
Commissioner, T.C. Memo. 2003-124. Respondent has produced such
information f…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent.
Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…