145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
…able]."
As of November 13, 2005, 2006, and 2007, the cash values of the
Tomassetti policy were $184,629, $251,559, and $314,120, respectively.
4. T. Tomassetti
Thomas Tomassetti (T. Tomassetti) was a nonshareholder employee of
Environmental. He was born on February 15, 1963.
Fifth Third Bank of Florida purchased a Minn…
IRCCourt RulingsOct 4, 1979
…, M.D., Inc. v. Commissioner, 69 T.C. 1055, 1057-1058 (1978); Packard v. Commissioner, 63 T.C. 621, 629 (1975).
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
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…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
IRCCourt RulingsOct 29, 2002
…r, T.C. Memo. 1997-171, affd. without published
opinion sub nom. Boccardo v. Commissioner, 164 F.3d 629 (9th Cir.
1998), support his contention that he constructively received all
of the lottery winnings in 1989 when he received offers to buy
the future lottery payments. We disagree. In Cowden, the Court
042 held that …
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner IRCCourt RulingsFeb 2, 2022
…oceeds from a Fidelity section 401(k) account of $154,156; a Bank of America account
balance of $56,629; veterans’ benefits, Social Security benefits, and employer vacation
pay of $5,489; and 2016 distributions from a Fidelity account of $7,722. Appeals
Officer Duff then reduced the sum of those amounts ($223,996) by “…
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 RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsMar 31, 1961
… 1, 035. 69
Total_ 780,100. 40 341, 117. 36 438, 983. 04
Less royalties_ 22, 895. 89 5, 266. 05 17, 629. 84
Gross income — adjusted_ 757, 204. 51 335, 851. 31 421, 353. 20
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
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…
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 RulingsJun 13, 1977
… the common law concepts used in making such a determination. Packard v. Commissioner, 63 T.C. 621, 629 (1975). Whether or not two parties stand in an employer-employee relationship is a factual question. Simpson v. Commissioner, 64 T.C. 974, 984 (1975); Ellison v. Commissioner, 55 T.C. 142, 152 (1970); James v. Commis…
IRCCourt RulingsJun 1, 2011related by meaning
n; thereafter, all amounts
received would be fully includable in gross income. Id.
However, this provision was repealed by the Tax Reform Act of
- 7 - 1986, Pub. L. 99-514, sec. 1122(c) (1), (h) (1)-(7), 100 Stat.
2467, 2470.5
Petitioners should understand that the Tax Court is a court
of limited jurisdiction and that …
IRCCourt RulingsMay 14, 2012related by meaning
etitioner does not cite any relevant law to establish her position. We
similarly find none; and in the absence of congressional intent we note that we have strictly construed section 104(a)(1) to conform to the general purview of
section 61, that all income is taxable unless explicitly excluded. See Baldwin v.
Commissi…
IRCCourt RulingsMar 5, 1987
…urnetta, O.D., P.A. v. Commissioner, 68 T.C. 387, 397 (1977); Packard v. Commissioner, 63 T.C. 621, 629 (1975). Accordingly, we hold that the common law definition of employee shall be utilized for purposes of section 219.
In determining the existence of a common law employer-employee relationship, “the crucial test li…
IRCCourt RulingsJul 11, 2012related by meaning
ditional tax provided by section 72(t)), penalties, and statutory
interest.. See Katz v. Commissioner, 115 T.C. 329, 338-339 (2000). The record
. 12 - does not establish that petitioners received a.notice of deficiency for 2007 and
consequently a challenge to petitioners' 2007 tax liability is allowed in thi
judicial p…