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98 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2026-93 — Aloke Pal v. Commissioner
    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…
  2. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  3. T.C. Summary Opinion 2002-33 — Wallace F. & Mi-Ja H. Smith v. Commissioner
    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
  4. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
    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…
  5. 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…
  6. 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.…
  7. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    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…
  8. 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…
  9. T.C. Memo. 2011-31 — Scott Ray Holmes v. Commissioner
    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…
  10. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    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’ …
  11. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    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 …
  12. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    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…
  13. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    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…
  14. 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…
  15. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    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…
  16. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    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…
  17. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    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…
  18. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    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…
  19. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    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…
  20. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    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…