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74 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2017-76 — Christopher S. Harrell, Sr. & Ingrid T. Harrell v. Commissioner
    IRCCourt RulingsMay 8, 2017
    …. Therefore petitioners are not entitled to a deduction under section 691(c). In any event, section 461(a) requires a taxpayer to deduct expenses for the year required under his or her method of accounting. A cash basis taxpayer generally must deduct his or her expenses for the year that payment of those expenses takes…
  2. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013
    03, 207-208 (1990); Commissioner v. Tufts, 461 U.S. 300, 307 (1983). Rather, petitioners were expected to pay back the loans to the insurance company. See Commissioner v. Tufts, 461 U.S. at 307. Where an insurance policy is terminated and the proceeds are used to satisfy a loan against the policy, the payment against t…
  3. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…
  4. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1 Unless otherwise indicated, all section references are to (continued...) T.C. Memo. 1999-199 UNITED STATES TAX COURT DON LAVERNE CLARKE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 151-97. Filed June 18, 1999. Don Laverne Clarke, pro se. Anthony Hoefer , for respondent. MEMORANDUM FINDINGS …
  5. 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…
  6. T.C. Summary Opinion 2009-77 — Gary W. & Regina G. Steele v. Commissioner
    IRCCourt RulingsMay 14, 2009
    …,150 payment was attributable to the payment of qualified residence interest . Furthermore, section 461(a) provides that deductions "shall be taken for the taxable year which is .the proper taxable year under the method of accounting used in computing taxable income ." Since petitioners are cash method calendar year ta…
  7. T.C. Summary Opinion 2002-108 — Claudia J. Dunn v. Commissioner
    IRCCourt RulingsAug 22, 2002
    …r the taxable year in which actually made”. Sec. 1.446-1(c)(1)(i), Income Tax Regs.; see secs. 446, 461; sec. 1.461-1(a)(1), Income Tax Regs. Petitioner’s higher education expenses for 1998 are limited to the qualified higher education expenses that she actually paid during 1998. Accordingly, only $261.47 of petitioner…
  8. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014
    …ommissioner v. Indianapolis Power & Light Co., 493 U.S. 203, 207-208 (1990); Commissioner v. Tufts, 461 U.S. 300, 307 (1983), because they were obliged to repay the loans to Northwestern, see Commissioner v. Tufts, 461 U.S. at 307. When an insurance policy is terminated and all or part of the proceeds are used to satis…
  9. T.C. Memo. 2010-42 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsMar 4, 2010
    …5 of which was taxable . Petitioner made no Federal income tax payments for 2003 apart from the $10,461 his employer withheld from his wages during the year . On his 2003 Form 1040, U .S . Individual Income Tax Return, petitioner reported zero wages and $2,735 of taxable pension and annuity income ; he claimed the stan…
  10. U.S. Tax Court — John C. Armbrust v. Commissioner
    IRCCourt RulingsJan 19, 2010
    …nt some constitut or ;ambiguous language, non limited to interpreting th Congress enacted it . Barn 461 '(2002) . _ The Supreme=C time and again that courts in a statute what it mean s there . When the words o first canon is also the-l a Id . .at 461-462 (quoting C o 249, 253-254 (1992)-) . the definition of IRAs .in s…
  11. T.C. Summary Opinion 2003-103 — Santos M. & Ingrid I. Castillo v. Commissioner
    IRCCourt RulingsJul 24, 2003related by meaning
    1 Unless otherwise indicated, section references hereafter are to the Internal Revenue Code in effect for the year at issue. T.C. Summary Opinion 2003-103 UNITED STATES TAX COURT SANTOS M. AND INGRID I. CASTILLO, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4698-02S. Filed July 24, 2003. Sant…
  12. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973
    … for the periods that such nonbusiness use applied. OPINION 1. Workmen's Compensation Issue Section 461, I.K.C. 1954, provides that a deduction allowed under the Code shall be taken for the taxable year which is the proper taxable year under the method of accounting used in computing taxable income. Under an accrual me…
  13. 62 T.C. 166; 14 U.C.C. Rep. Serv. (West) 1165 — Don E. Williams Co. v. Commissioner
    IRCCourt RulingsMay 14, 1974
    …axpayer incurs a liability to make the contribution, the amount of which is aecruable under section 461 for such taxable year. See section 461 and the regulations thereunder. There is another exception in the case of certain taxpayers who are required to make additional contributions as a result of the Act of June 15, …
  14. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  15. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …luation Date Boren Steel . 458 Hours of Service Citrus Valley . 460 Old Frontier. 460 Boren Steel . 461 Section 4972 Excise Tax. 461 Section 6651 Failure to File Addition to Tax . 462 Section 6659A Additions to Tax . 463 Conclusions . 465 OPINION Clapp, Judge: Respondent determined the following deficiencies in and add…
  16. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  17. 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 .
  18. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    ly $15,461.[194] Table 8—One-Time Burden and Cost To Provide Notice of Right To Designate a Primary Care Provider Year Estimated number of respondents Estimated number of responses Burden per response (hours) Total annual burden (hours) Total estimated labor cost Total estimated printing and materials cost Total estima…
  19. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
  20. T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
    IRCTreasury DecisionsSep 18, 2006
    …me item to a method of accounting utilizing the 31/2 month rule authorized by regulations section 1.461-4(d)(6)(ii) or the recurring item exception authorized by regulations section 1.461-5. Rev. Proc. 2006-12 modified. EMPLOYEE PLANS T.D. 9280 T.D. 9280 Final regulations under section 411(d)(6) of the Code provide gui…