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94 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020
    … case. Respondent determined that petitioners are liable for a Federal income tax deficiency of $28,896 for the taxable year 2013 (year in issue), an addition to tax for late filing under section 6651(a)(1) of $6,595, and an accuracy-related penalty under section 6662(a) of $5,779. Petitioners, husband and wife, filed …
  2. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020
    …r Courts of Appeals follow the same framework. See, e.g., Young v. United States, 332 F.3d 893, 895-896 (6th Cir. 2003); Edwards v. Valdez, 789 F.2d 1477, 1482-1483 (10th Cir. 1986); Grauvogel v. Commissioner, 768 F.2d 1087, 1089 (9th Cir. 1985); Richards v. Commissioner, 745 F.2d 524, 525-526 (8th Cir. 1984), affg T.C…
  3. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
  4. T.C. Memo. 2009-285 — Bill S. & Carolyn M. McGowen v. Commissioner
    IRCCourt RulingsDec 14, 2009
    … the policy, a requirement indicative of a bona fide debt . See Salley v . Commissioner , 55 T .C . 896, 903 (1971), affd . 464 F .2d 479 (5th Cir . 1972) ; Kay v . Commissioner , 44 T .C . 660, 670-672 (1965) ; Dean v . Commissioner , 35 T .C . 1083, 1085 (1961) . Consequently, petitioners would not have had to recogn…
  5. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  6. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987related by meaning
    GOFFE, Judge: The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
  7. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971
    …109 F. 2d 99, 100 (C.A. 2), certiorari denied 310 U.S. 637, and Estate of Dora N. Marshall, 51 T.C. 896, 701-702.
  8. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014
    …e debt. See McGowen v. Commissioner, 2009 WL 4797538, at *3 (citing Salley v. Commissioner, 55 T.C. 896, 903 (1971), aff'd, 464 F.2d 479 (5th Cir. 1972), Kay v. Commissioner, 44 T.C. 660, 670-672 (1965), and Dean v. Commissioner, 35 T.C. 1083, 1085 (1961)). Pursuant to the policy's terms, amounts borrowed, as well as i…
  9. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    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…
  10. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    …Active employees 652,308 1,710,610 2,362,918 CD Retirees 8,892,721 22,637,914 31,530,635 CO 05 00 9,896,844 25,405,545 35,302,389 Petitioner contributed $35,300,000 to the VEBA trust on December 29, 1986. Petitioner claimed a deduction for the full amount of the November and December 1986, contributions to the VEBA tru…
  11. 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…
  12. T.C. Summary Opinion 2013-42 — Aster Tirfe v. Commissioner
    IRCCourt RulingsJun 3, 2013related by meaning
    T.C. Summary Jpinion 2013-42 UNITED STATES TAX COURT ASTER TIRF E, Petitioner v. COMMISSIONER OF INTE 1NAL REVENUE, Respondent Docket No. 25865-10S. Filed June 3, 2013. Aster Tirfe, pro se. Steven Roth, for respondent. SUMMARlY OPINION CARLUZZO, Special Trial Judge This case was heard pursuant to the provisions of sect…
  13. T.C. Summary Opinion 2005-108 — Magellean Askew, Jr. v. Commissioner
    IRCCourt RulingsAug 1, 2005
    …nalty Distribution 2 7142446 Jun 11 $12,434 3 $6,429 $6,005 $2,126 $3,879 7142859 Jun 26 10,590 4 8,896 1,694 858 836 7166534 Jun 11 4,700 -0- 4,700 592 5 3,286 1 Cash value equals accumulated cash value less loan payoff value. 2 Net distribution equals cash value less surrender penalty. 3 On June 14, 1999, College Lif…
  14. T.C. Memo. 1998-399 — Ronny H. & Charlotte A. Schmalzer v. Commissioner
    IRCCourt RulingsNov 10, 1998related by meaning
    tstanding rollover involved in this case. Accordingly, the amount of excludable basis in the instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is $1,950 and the denominator of which is $1,374.53 plus $6,100, resulting in an amount excludable of $1,591.40.…
  15. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  16. 74 T.C. 651 — Judd v. Commissioner
    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…
  17. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    r's Life. Respondent further determined that petitioner is liable for the addition to tax under section 6651(a) for his failure to file a 1992 Federal income tax return. - 5 - OPINION Petitioner does not deny receipt of any of the items of income. Nor does he claim that any particular item of income has been overstated…
  18. 125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner
    IRCCourt RulingsNov 17, 2005
    …ch such property could be put on the date of valuation. See Symington v. Commissioner, 87 T.C. 892, 896 (1986). In the case of real property, the highest and best use of the land may need to take 8Although agreeing with the premise that these principles should be taken into account in valuation, this Court ultimately f…
  19. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    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…
  20. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015
    …d from the sale of qualified export property under section 993(c). It claimed a deduction of $2,150,896 for DISC commissions. Protective Refund Claims On July 9, 2012, respondent issued JC Holding a letter apprising it of its right to file a protective refund claim for income tax reported on its 2008 Form 1120. In Augu…