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87 documents · 0.78sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1998-172 — Richard S. & Bernice F. Roberts v. Commissioner
    IRCCourt RulingsMay 11, 1998
    …has yet been devised which is free of all discriminatory impact.’” Druker v. Commissioner , 77 T.C. 867, 872 (1981) (quoting San Antonio Indep. Sch. Dist. v. Rodriguez , 411 U.S. 1, 41 (1973)), affd. in part on this issue and revd. in part on another issue 697 F.2d 46 (2d Cir. 1982). Petitioner’s argument stems from th…
  2. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  3. T.C. Memo. 1996-378 — Gaylord W. Greenlee v. Commissioner
    IRCCourt RulingsAug 15, 1996related by meaning
    c. Year 6651(a)(1) 1985 $ 813 1986 1,123 1987 1,403 1988 1,529 1989 1,581 1990 1,539 Then, in her reply brief, she conceded that the correct additions to tax are as stated in the text. The primary issue for decision is whether petitioner engaged in a prohibited transaction so as to be subject to the first-tier excise t…
  4. T.C. Memo. 2016-33 — Sally M. Costello v. Commissioner
    IRCCourt RulingsMar 1, 2016
    …r the circumstances to wind up the affairs of the trust."); Sterling v. Sterling, 194 Cal. Rptr. 3d 867, 879 (2015) (equating Cal. Prob. Code sec. 15407(b) with Restatement, Trusts 3d, sec. 89 (2007), which states that "[t]he powers of a trustee
  5. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    T.C. Memo. 1998-203 UNITED STATES TAX COURT RAMON A. GARCIA AND BERTHA E. GARCIA, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21532-95. Filed June 3, 1998. Richard M. Taylor and James E. McCutcheon III , for petitioners. Elizabeth A. Owen , for respondent. MEMORANDUM FINDINGS OF FACT AND OPI…
  6. T.C. Memo. 2016-15 — Robert Leon Martin v. Commissioner
    IRCCourt RulingsFeb 3, 2016
    …or us to estimate Martin's losses from slot-machine gambling. See Schooler v. Commissioner, 68 T.C. 867, 869-871 (1977). We hold that the gambling winnings of $1,000 are includible in Martin's income for the 2011 taxable year. - 9 - [*9] In reaching our holdings, we considered all arguments made, and, to the extent not…
  7. T.C. Memo. 2022-3 — John M. Larson v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …owed deferral of Mr. Larson’s distributive share of Morley income, resulting in defic iencies of $6,867,653, $2,431,749, and $1,253,344 for the 1999, 2000, and 2001 tax years, respectively. The first issue for decision is whether respondent erred in determining that Mr. Larson’s stock in
  8. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
  9. 64 T.C. 1011 — Catawba Industrial Rubber Co. v. Commissioner
    IRCCourt RulingsSep 9, 1975
    … Inc., 15 T.C. 671 (1950); Crow-Burlingame Co., 15 T.C. 738 (1950); Dejay Stores v. Ryan, 229 F. 2d 867 (2d Cir. 1956); Tallman Tool & Machine Corp., 27 T.C. 372 (1956), and also, since petitioner’s contribution was not paid within its taxable year ending April 30, 1972, whether the contribution was an accruable item f…
  10. 85 T.C. 869; 85 T.C. No. 51 — Griswold v. Commissioner
    IRCCourt RulingsNov 26, 1985related by meaning
    idual retirement annuities, such as section 408(d), can have no application with respect to petitioner’s annuity contract on or after January 1, 1980. Thus, we hold that under section 408(e)(3), petitioner’s borrowing against the annuity contract with John Hancock during 1980 caused the contract to cease being an indiv…
  11. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
  12. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020
    …* has yet been devised which is free of all discriminatory impact." Druker v. Commissioner, 77 T.C. 867, 872 (1981) (quoting San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1, 42 (1973)), aff'd in part on this issue, rev'd in part on another issue, 697 F.2d 46 (2d Cir. 1982). In short, Ms. Conard has failed to car…
  13. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
  14. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010
    …greement, the allegations in the complaint, and-the amount paid . Green v . Commissioner , supra at 867 ; Robinson v . . Commissioner ,, 102 T .C . 116, 127 (1994),,affd . in part, revd . in part and remanded on another issue .70 F .3d 34, (5th Cir . 1995) ; Stadnyk v . Commissioner , T .C . Memo . 2008-289, affd . wit…
  15. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    e within the parameters spelled out in section 404(a)(6), may be deducted in the prior year, but only if they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
  16. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …, the Department estimates that 812 mutual fund companies will be affected by the amended PTE 77-4.[867] PTE 80-83 allows banks to purchase, on behalf of employee benefit plans, securities issued by a corporation indebted to the bank that is a party in interest to the plan. The Department estimates that 19 small fiduci…
  17. T.C. Memo. 2009-140 — James A. Haigh v. Commissioner
    IRCCourt RulingsJun 15, 2009
    …f $18,437 and $2,788 .13, respectively, adjusted gross income of $54,972 .01, taxable income of $29,867 .61, and total tax of $3,766, an d (3) claimed total tax payments of $5,91 .40and a refund due of $2,144 .40 . In the 2004 joint return, t' e Haighs did~not repor t any additional tax imposed by section 7 ?(t) (10-pe…
  18. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012
    …excise tax, of $879,468 and a failure to pay addition to tax pursuant to section 6651(a)(2) of $219,867.6 . . Discussion I. Burden of Proof As a general.rule the taxpayer bears the burden of proving that the Commissioner's determinations are erroneous. Rule 142(a)(1); Welch v. Helvering, 290 U.S. 111, 115 (1933). . 4Th…
  19. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  20. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    …00.4(c) introductory text 5,903 6,052 § 100.4(c) introductory text 70,834 72,620 § 100.5(c) 7,673 7,867 § 100.5(d) 324 332 § 100.5(e) 259,725 266,275 Title 41—Public Contracts and Property Management PART 50-201—GENERAL REGULATIONS 35. The authority citation for part 50-201 continues to read as follows: Authority: