IRCCourt RulingsSep 24, 2026
…im of systematic hate/discrimination” because he had filed whistleblower claims
regarding Boeing’s “737 Max Program . ” He alleged that he had not received a Form 1099 – R reporting any distributions for 2021 and that ( in
any event) he “ did not recognize ACCT number on the 1099– R.”
On August 26, 2025, r espondent is…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsApr 3, 2002
…t
petitioners' arguments possess some measure of colorable merit.
- 9 -
See Crain v. Commissioner
, 737 F.2d 1417 (5th Cir. 1984). In
short, petitioners are taxpayers subject to the income tax laws
IRCCourt RulingsMay 31, 1989related by meaning
nal Revenue Code of 1954 as amended and in effect at the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Sec. 7482(b)(1)(A) establishes venue for appeal in the case of a petitioner other than a corporation. While the parties stipulated that petitioner’s principal office was…
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…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
f this title, section 529 of title 81, or section 259 or 267 of title 40, and before approval of title to the underlying land by the Attorney General. There seem to be discrepancies in the figures stipulated by the parties, used by petitioner in reporting income on its tax returns, and employed by the parties on brief.…
IRCCourt RulingsJan 5, 2017
… to do so might suggest that these arguments have some
colorable merit." See Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir.
1984); Wnuck v. Commissioner, 136 T.C. 498 (2011). Consequently, we uphold
respondent's determinations with respect to petitioner's wage income for 2010 and
2011.
III. IRA Distribution
Petit…
50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner IRCCourt RulingsMay 29, 1968related by meaning
-10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
IRCCourt RulingsFeb 1, 2011
…ner's
groundless and frivolous assertions warrant no further
discussion. See Crain v. Commissioner, 737 F.2d 1417, 1417 (5th
Cir. 1984) ("We perceive 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 merit.").
Petit…
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 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…
IRCCourt RulingsOct 29, 2013related by meaning
ed CST, an entity owned by his IRA, to enter into a lease agreement
with CDJ, an entity owned by both petitioners and their children in tax year 2006. The notice of deficiency also reflected respondent's determination that, for
the year in which the prohibited transaction occurred petitioners are liable for the
additio…
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…
IRCCourt RulingsFeb 10, 1997related by meaning
Judicial Notice Motions.
- 4 -
Rule 201(f) of the Federal Rules of Evidence provides that
judicial notice may be taken at any stage of the proceeding. Petitioner's Judicial Notice Motions will be denied in this case,
however, because their many paragraphs constitute nothing more
than a hodgepodge of argument and statem…
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
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…
IRCCourt RulingsNov 14, 1996related by meaning
committee was making a
change only in the timing
of the deduction in respect of vacation
pay in contrast to the timing of other deferred compensation payments, and then only in the context of clear recognition that
its change applied only to payments after the 2-1/2 month period.
Having found our way through the statu…
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…