IRCCourt RulingsMay 19, 2011
…se arguments
7 -
because to do so'might suggest that they have merit. Accord
Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984).
II. Unreported Income
As a general rule, the Commissioner's determinations in a
notice of deficiency are presumed correct, and the taxpayer bears
the burden of proving these determinations …
IRCCourt RulingsJul 13, 2010
…o "might
suggest that these arguments have some colorable merit : ." See Crain v . . Commissioner , 737 F .2d 1417 ., .1417 ( 5th Cir . - 1984) .
Accordingly , we uphold respondent ' s determination that Mr .
O'Boyle had-taxable income- . of $13,57 . 7 for ° 2002 from the sale of .
securities . . We conclude that petit…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsDec 22, 2008
…;
to do so might suggest that these arguments have some
colorable merit ." Crain v . Commissioner , 737 F .2d 1417, 1417
(5th Cir . 1984 ) . On the basis of the foregoing , we sustain
respondent's determination of petitioner ' s unreported income .
III . Section 72(t )
Section 72 (
t) provides for a 10-percent addition…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsAug 30, 2006
…ystem of Baltimore
County (ERS), (2) whether petitioners overstated Catherine E.
France’s wages by $737 on their 2000 Federal income tax return,
and (3) whether we have jurisdiction over a deficiency in
petitioners’ 1997 income tax.
4
The findings of fact and conclusions relevant to each issue
are summarized below. Pet…
IRCCourt RulingsApr 2, 2024
…iction over
any suit for the purpose of restraining the assessment or collection of
any tax. Id. at 737, 749; see also Maze v. IRS , 862 F.3d 1087, 1091 (D.C.
Cir. 2017); Cohen v. United States, 650 F.3d 717, 729 (D.C. Cir. 2011).
In Williams Packing & Navigation Co. , 370 U.S. at 7, the Supreme Court
stated that if th…
Notice 2026-34 — 2026 Cumulative List of Changes in Plan Qualification Requirements for Defined Benefit Qualified Pre-approved Plans IRCNoticesJun 1, 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 RulingsMay 13, 1999
…ept. 104-586 at 112 (1996), 1996-3 C.B.
331, 450; S. Rept. 104-281 at 80 (1996); H. Conf. Rept. 104-737
at 245-246 (1996), 1996-3 C.B. 741, 985-986.
Contributions made by the employer to a plan of
deferred compensation to the extent that, before
the application of the section 415 limitations to
that plan, the contribut…
IRCCourt RulingsDec 11, 1997
…rmined in the notice, inter alia, that for 1991, 1992, and 1993 petitioners are
not entitled to $96,737, $81,165, and $31,712, respectively, of
the interest deductions that they claimed in Schedules A of their
returns for those years. The following explanation was set forth
in the notice for the disallowance of those c…
IRCCourt RulingsFeb 2, 2022
…e share s of Morley income for 1999, 2000, and 2001 from zero to
$8,915,329, $4,265,220, and $2,790,737, respectively (i.e., 33.33% of
Morley’s reported income for the relevant taxable years) .
7
The IRS also
6
Mr. Larson, through his counsel, filed protective refund claims on Forms
1040X, Amended U.S. Individua l Inco…
IRCCourt RulingsJun 23, 2025
…ds of cases, and we will not dignify his position with further
response. See Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir.
1984) (per curiam) (“We perceive no need to refute these arguments with
somber reasoning and copious citation of precedent . . . .”); see also
Wnuck , 136 T.C. at 501 – 13 (explaining why co…
IRCCourt RulingsJul 9, 1997
…dition to Tax
Sec. 6654
1987 $24,520 $4,748 $361
1988 20,939 3,124 738
1990 20,349 3,925 998
1991 6,737 1,460 331
1992 4,554 1,105 192
Petitioner Joan E. Murtaugh:
Year Deficiency
Addition to Tax
Sec. 6651(a)
Addition to Tax
Sec. 6654
1987 $2,075 $100 $0
1988 1,901 29 0
1992 3,098 168 0
Unless otherwise noted, all sect…
IRCCourt RulingsSep 26, 2001related by meaning
effect, rewrite
the statute to achieve what seems to be a more equitable result.
See Eanes v. Commissioner
, supra
at 171. “Whether and to what
- 6 - extent deductions shall be allowed depends upon legislative
grace; and only as there is clear provision therefor can any
particular deduction be allowed.” New Colonial Ic…
IRCPrivate Letter RulingsDec 2, 2005related by meaning
- -
- - -
IRCCourt RulingsNov 9, 2020
…ner's other arguments are frivolous and warrant no further discussion.
S_e_e Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) ("We perceive
- 6 -
[*6] no need to refute these arguments with somber reasoning and copious citation
of precedent; to do so might suggest that these arguments have some colorable
meri…
IRCCourt RulingsJul 22, 1999
…nt; to do so might
suggest that these arguments have some colorable merit." Crain
v. Commissioner
, 737 F.2d 1417, 1417 (5th Cir. 1984).
Accordingly, we sustain respondent's determination that these
amounts are income.
- 5 -
2
Respondent, in the separate notices of deficiency sent to
Mr. Morin and Mrs. Morin, determine…
IRCCourt RulingsFeb 4, 1998
…nt; to do
so might suggest that these arguments have some colorable merit."
Crain v. Commissioner
, 737 F.2d 1417, 1417 (5th Cir. 1984).
Section 61(a) defines an individual's gross income as "all
income from whatever source derived". Respondent determined that
compensation for services, gains derived from dealings in
-…