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  1. T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner
    IRCCourt RulingsFeb 23, 2022
    …have jurisdiction. Hambrick v. Commissioner, 118 T.C. 348, 350 (2002); Pyo v. Commissioner, 83 T.C. 626, 632 (1984); Kluger v. Commissioner, 83 T.C. 309, 314 (1984). Even where the parties do not raise the issue, as in this case, we are required to resolve a question as to our jurisdiction on our own initiative. Powell…
  2. 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…
  3. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
  4. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996
    …ship form satisfied the formality of separation from the service. Burton v. Commissioner , supra at 626. After reviewing the continuity between Burton's practice as a professional association and the subsequent practice as a sole proprietorship, we concluded that there was only a technical change in the employment rela…
  5. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010related by meaning
    a reasonable .dispute with respect to any item of income reported on an information return filed with the Secretary by a third party :and the taxpayer has "fully cooperated with the Secretary (including providing,,-, within ,a reasonable period-of time, access to and inspection of, all witnesses, information, and docum…
  6. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995
    …ternal Revenue Code or in the accompanying regulations. 9 See Burton v. Commissioner , 99 T.C. 622, 626 (1992). The burden of proving that the Transfer Refund was received "on account of" petitioner's separation from the service is on petitioners. Rule 142(a); Burton v. Commissioner , supra at 632; Sarmir v. Commission…
  7. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    on? We hold that it does. 2. Did petitioners, within the meaning of section 4975(f)(5), correct the prohibited transaction? We hold that they did not. 3. What is the "amount involved" relating to a loan that is subject to section 4975 excise taxes? We hold that the "amount involved" is the greater of the interest paid …
  8. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …es), affg . T .C . Memo . 32 - 1975-92 ; W & W Fertilizer Corp . v . United States , 527 F .2d 621, 626 (Ct . Cl . 1975) (trusts, but not custodians, count as real parties in interest for consenting to subchapter S status) ; 'Kean v . Commissioner , 469 F .2d 1183, 1187 (9th Cir . 1972) ("`shareholders' who must file-a…
  9. U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner
    IRCCourt RulingsJun 26, 2018
    …Mr. Essy's wages were $41,557 and $40,000 in 2000 and 2001, respectively. Petitioner contributed $1,626.92 to Mr. Essy's account for the plan year ending March 31, 2001, and $500 for the plan year ending March 31, 2004. Petitioner made no contributions during the plan years ending March 31, 2002 and 2003. Mr. Essy's ac…
  10. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011
    …paration from service as the point when an employee severs his connection with his employer. Id. at 626. Because of ongoing litigation over his removal, as well as the MSPB decision ordering his reinstatement, petitioner argues "In that case, we concluded that an individual's change from employee status to sole proprie…
  11. 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 …
  12. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998
    …, and 6214; see also Cross v. Commissioner , 98 T.C. 613, 615 (1992); Pyo v. Commissioner , 83 T.C. 626, 632 (1984). - 5 - 3 Among other things, petitioner makes the following arguments: That wages are not taxable income, and that the Forms W-2 show only "employment taxes withheld" and not any kind of tax owed by him. …
  13. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998
    …r to extend the 90-day period for filing a petition. Rule 25(c); see P yo v. Commissioner , 83 T.C. 626, 632
  14. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  15. 48 T.C. 75 — Pepsi-Cola Niagara Bottling Corp. v. Commissioner
    IRCCourt RulingsApr 26, 1967
    …loyed in 1961. The highest paid of these eight employees received from petitioner wages totaling $6,626.02 for 1961, $7,128.93 for 1962, and $7,342.94 for 1963. The lowest paid of these employees received wages totaling $3,968.96 for 1961, $4,160 for 1962, and $4,420 for 1963. The remainder of these employees received …
  16. T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner
    IRCCourt RulingsMar 5, 2007
    …f January 7, 2003, petitioner and intervenor owed tax, penalties, and interest in the amount of $27,626.39 for 1992, $34,170.77 for 1993, $21,804.15 for 1994, $2,719.74 for 1995, and $11,351.78 for 1996 for a total of $97,668.83. OPINION A. Background If husband and wife file a joint Federal income tax return, they are…
  17. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …0,000 $13,067,430 2004 14,595,000 14,055,577 43n the 2004 Form 1120S, Weekend Warrior reported a $1,626,198 deduction for designer costs and a $2,968,802 deduction for marketing services. During- the years at issue Weekend Warrior claimed depreciation deductions with respect to the airplane as follows: Year Special dep…
  18. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013related by meaning
    T.C. Summary Opinion 2013-96 UNITED STATES TAX COURT SAMUEL BRACH AND LILLIAN BRACH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15460-12S. Filed December 2, 2013. Ronald Jay Cohen, for petitioners. Gennady Zilberman, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was h…
  19. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …EO 1989 162.416 343.92 522.82 701.72 Non-Durable Goods Manufacturing CEO 1989 162.416 351.03 488.82 626.61 All Non-Manufacturing CEO 1989 162.416 343.83 488.25 632.67 Wholesale Trade CEO 1989 162.416 380.49 580.02 779.55 Services CEO 1989 162.416 362.71 508.11 653.51 Business Services CEO 1989 162.416 359.46 497.23 634…
  20. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…