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41. T.C. Summary Opinion 2005-114 — Francis N. & Patricia A. Leonard v. Commissioner
    IRCCourt RulingsAug 4, 2005
    …en the alleged casualty and the loss claimed by the taxpayer. Kemper v. Commissioner , 30 T.C. 546, 549-550 (1958), affd. 269 F.2d 184 (8th Cir. 1959). Whether damage qualifies as a casualty typically turns on whether the damage satisfies the suddenness requirement, which denotes an accident, a mishap, or some sudden i…
42. T.C. Memo. 2005-5 — Thomas G. Wright and Estate of Rosemary K. Wright, Deceased; Thomas G. Wright, Personal Representative v. Commissioner
    IRCCourt RulingsJan 13, 2005
    …36, 938-939 (6th Cir. 1991), affg. T.C. Memo. 1989-654; Caplin v. United States , 718 F.2d 544, 548-549 (2d Cir. 1983); Wood v. United States , 590 F.2d 321, 323 (9th Cir. 1979). Additionally, section 105(e)(2) provides that amounts received under a disability fund maintained under State law are treated as received thr…
43. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001related by meaning
    claim to a pension plan contribution deduction on that ground forecloses her claim that she is entitled to an above-the-line Schedule C deduction for legal fees, rather than the itemized deduction subject to the 2percent limitation of section 67 that respondent allowed in the statutory notice. To give effect to all the…
44. T.C. Summary Opinion 2003-1 — Nell B. Newell v. Commissioner
    IRCCourt RulingsJan 7, 2003
    …he year in issue. - 2 - Respondent determined a deficiency in petitioner’s Federal income tax of $1,549 for the taxable year 1999. The issue for decision is whether amounts petitioner received pursuant to a divorce decree are includable in her income as pension income or, alternatively, as alimony income. Some of the f…
45. T.C. Summary Opinion 2001-158 — Majid Naemi v. Commissioner
    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…
46. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    … gain determined by respondent and that calculated by petitioners results from (1) a difference of $549.09 in the original cost of the property, (2) a difference of $1,212.75 in the depreciation of the property, and (3) an alleged loan of $4,700 that petitioner subtracted from the selling price to arrive at the amount …
47. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988related by meaning
    e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted. An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
48. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …cial scrutiny to determine whether a purported loan was actually a gift. Caligiuri v. Commissioner, 549 F.2d 1155, 1157 (8th Cir. 1977), affg T.C. Memo. 1975-319. A transfer between family members is presumed for tax purposes to be a gift. Perry v. Commissioner, 92 T.C. 470, 481 (1989), aff'd without published opinion,…
49. T.C. Memo. 2007-90 — Roger F. & Mary A. Duronio v. Commissioner
    IRCCourt RulingsApr 17, 2007related by meaning
    iable for the $1,990 10-percent additional tax on the $19,900 early IRA distribution Mary received. To reflect the foregoing, Decision will be entered under Rule 155 .
50. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …., docket No. 25764-10 Accuracy-related penalties Year Deficiency Sec. 6662(a) Sec. 6662A 2005 $114,549 $22,910 -02006 193,029 38,606 -02007 45,184 -0- $15,750 Blakes, docket No. 25765-10 Accuracy-related penalties Year Deficiency Sec. 6662(a) Sec. 6662A 2005 $276,032 $55,206 -02006 402,643 80,529 -02007 428,303 -0- $8…
51. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
52. 38 T.C. 312 — Hydro Molding Co. v. Commissioner
    IRCCourt RulingsMay 28, 1962related by meaning
    ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
53. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    … exemption changes Cost savings   (A) (B) (A−B) Traditional VFC Program (annual) $765,570 $215,876 $549,693 SCC (annual) 355,910 −355,910 VFCP Exemption (annual) 120,236 120,236 0 Total (annual) 885,806 692,023
54. T.C. Summary Opinion 2004-1 — Lawrence K. Mudd v. Commissioner
    IRCCourt RulingsJan 8, 2004
    … subject to substantial limitations or restrictions. Id. ; Single v. Commissioner , T.C. Memo. 1988-549. We first address the $32,500 which petitioner authorized First National to transfer to the Cincinnati bank in 1993. Respondent argues that this amount is includable in petitioner’s - 7 - income in 1995, the year in …
55. T.C. Memo. 2012-311 — Charles L. Hartley v. Commissioner
    IRCCourt RulingsNov 6, 2012related by meaning
    taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross mcome. Exceptions to this rule are found in section 72(t)(2). Petitioner has not identified any exception applicable to this case, nor have we. Regarding petitione…
56. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …e Departments estimate an annual burden of 15,345 hours, with an associated total annual cost of $1,549,606 beginning in 2024.
57. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999
    … (3d Cir. 1986), vacating and remanding T.C. Memo. 1985-101; and Gerardo v. Commissioner , 552 F.2d 549 (3d Cir. 1977), affg. in part, revg. in part and remanding T.C. Memo. 1975-341, petitioner takes the position that the determinations made in the notice of deficiency in this case are arbitrary and excessive, and the…
58. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
59. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999
    …1,161 The FUH plan paid Travelers the following amounts for renewal premiums: Date Premiums 9/6/83 $549,699 7/23/84 556,843 9/6/85 554,390 8/26/86 554,390 8/28/87 530,650 8/31/88 526,325 6. Commissions Paid by Travelers to the Garrahan Agency During the years at issue, the Garrahan Agency received the following amounts…
60. 88 FR 11984 — Annual Information Return/Reports
    IRCFinal Rules (FR)Feb 24, 2023
    …nstitutions, Businesses or other for- profits. Total Respondents: 809,901. Total Responses: 178,211,549. Frequency of Response: Annually. Estimated Total Burden Hours: 1,114,751. Total Annualized Costs: $18,423,119.