IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
IRCCourt RulingsAug 22, 1994
… 40,711,951 44,624,024 45,382,893
Expenses 147,753 72,543 167,565
Total disbursements 40,859,704 44,696,567 45,550,458
Net increase (decrease) of assets (12,367,619) (29,557) (1,194,923)
Assets at end of period 1,967,062 1,937,506 742,583
OPINION
IRCCourt RulingsJan 29, 2019
…ntitled to reimbursement from his employer for such expenses. See
Fountain v. Commissioner, 59 T.C. 696, 708 (1973). The taxpayer can prove that
he is not entitled to reimbursement by showing, for example, that he is expected to
bear these costs. See id. at 708. An expense for which the taxpayer is entitled to
(but doe…
IRCCourt RulingsMar 7, 2000
…rit. Rowlee v..Commissioner, 80 T.C. 1111 (1983);
McCoy v. Commissioner, 76 T.C. 1027 (1981), affd. 696 F.2d 1234
(9th Cir. 1983). We see no need to repeat these discussions
here.
Suffice it to say that petitioner is not exempt from having
to pay Federal income taxes.· Abrams v. Commissioner, 82 T.C.
403, 407 (1984). P…
IRCCourt RulingsSep 19, 2019related by meaning
e. Because petitioner raises only a legal issue, we
decide whether he is liable for the deficiency without regard to the burden of
proof.
II. Analysis Gross income generally includes distributions from an IRA under the
provisions of section 72. Sec. 408(d); see Sears v. Commissioner, T.C. Memo.
2010-146. Section 72(t)(…
IRCCourt RulingsNov 26, 2014
…, at 114 (1973), 1974-3 C.B. (Supp.) 80, 193; see
also Wenzel v. Commissioner, * * * [707 F.2d 694, 696 (2d Cir.
1983), aff'g T.C. Memo. 1982-595]. Therefore, discovery or
_ 9 _
introduction of extrinsic evidence in such cases is inconsistent with
the legislative intent that such cases be resolved without a trial based…
78 FR 13797 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements ERISAFinal Rules (FR)Mar 1, 2013
…l premium for single coverage was $4,717 and the average annual premium for family coverage was $12,696.[11]
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
Atkins, Judge:
The respondent allowed claims for net renegotiation rebates for the calendar years 1942, 1943, and 1944 in the respective amounts of $2,163.21, $87,717.10, and $167,421.69. The petitioner alleges that the respondent erred in failing to allow net renegotiation rebates for those years in the respective amo…
78 FR 13781 — Filings Required of Multiple Employer Welfare Arrangements and Certain Other Related Entities ERISAFinal Rules (FR)Mar 1, 2013
…ge single coverage annual premium was $4,717 and the average annual family coverage premium was $12,696.[29]
IRCCourt RulingsMay 22, 2025
…case the investment bank reduced the revenue projections in Facebook’s
Base Case for each year: by $696 million (18.56%) in 2011, $1.667 billion
(27.78%) in 2012, and $3.235 billion (32.35%) in 2013. The investment
bank applied this haircut to Facebook’s projected Base Case revenue for
two reasons , explained at trial …
IRCCourt RulingsOct 2, 1974
…2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.C. 119 (1971); and C. D. Fountain, 59 T.C. 696 (1973). Sec. 267(a)(2) disallows deductions for items of unpaid expenses and interest on stated conditions. One of the conditions requires consideration of whether the amounts of the disputed items are includable in …
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 RulingsJun 18, 1997related by meaning
1
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Responden…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCCourt RulingsMay 17, 1973related by meaning
was “earned income” within the ambit of section 911 (b) and is excludable from gross income to the extent of $25,000 per year under section 911 ('a). Petitioner has claimed overpayments of $5,517 for 1965 and $7,040.82 for 1966. As to the first amount, it is stipulated that the petitioner overstated his gross income f…
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…arge
IT
158
81.8
84
12,926
1,085,686
Benefits
158
59.5
62
9,401
585,964
Legal
158
7.4
130
1,175
152,696
Sub-Total
23,503
1,824,346
Medium:
IT
526
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
ment 2009-88 Announcement 2009-88
A list is provided of organizations now classified as private foundations.
Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
IRCCourt RulingsJan 16, 1963
…$1,971.75 $3,261.85
1953_ 12,688.86 1,006.26
1954_ 28,515.19 384.05
1955_ 774.93 6, 779.47 1956_ 8, 696.74 8,758.76
2,949.76 5,402.33
1958_ 10,160.79 3,924.14
During those years the petitioner made deductible charitable contributions to donees other than the Fund as follows:
Year: Amount
1952_ $6, 075. 00
1953_ 8, 768.…
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
IRCCourt RulingsMay 12, 1971
…ed applicable in a wide variety of other situations. Cf., e.g., Estate of Dora N. Marshall, 51 T.C. 696, 700-702; Estate of Grace D. Sinclaire, 13 T.C. 742, 746; Estate of Cornelia B. Schwartz, 9 T.C. 229, 237-239; Estate of George W. Hall, 6 T.C. 933, 939. Throughout this line of cases is the underlying concept, artic…