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41. T.C. Memo. 1996-267 — G. Richard & Sara B. Childs v. Commissioner
    IRCCourt RulingsJun 11, 1996
    …o. 1995-27; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; Conway v. United States , 908 F. Supp. 292 (D. Md. 1995); Maryland State Teachers Association v. Hughes , 594 F. Supp. 1353, 1357-1358 (D. Md. 1984). 3 See sec. 414(h)(2). Petitioner's election to transfer from the …
42. 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’ …
43. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
44. 114 T.C. No. 17 — Michael G. Bunney v. Commissioner
    IRCCourt RulingsApr 10, 2000
    … of community property rights in an IRA for State law purposes. 3 See In re Mundell , 857 P.2d 631, 633 (Idaho 1993) (community property interest in wife’s IRA is includable in - 6 - 4 Sec. 402(b)(2) provides that “The amount actually distributed or made available to any distributee by * * * [an employee’s trust] shall…
45. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
46. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
47. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
48. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    …spect to the nature of the interest paid. Rule 142(a); Cannizzaro v. Commissioner , T.C. Memo. 1982-633; see also King v. Commissioner , 89 T.C. 445, 456-467 (1987). Consequently, we hold that petitioner is entitled to deduct investment interest expenses
49. 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…
50. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025
    …idently divided the amount by six , arriving at an erroneous amount of total monthly income of $123,633. AO Alves then reduced that amount by the amount of total expenses of $113,351 , which he calculated through the same
51. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015
    …on of taxes with the taxpayer's concerns regarding the intrusiveness of the collection action. Sec. 6330(c)(3). II. Standärd of Review If the taxpayer disagrees with Appeals' determination, the taxpayer may seek review of the determination by filing a timely petition in this Court. Secs. 6320(c), 633 (d). If a taxpayer…
52. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
53. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …did not disclose his participation in the Sterling Plan. The Blakes reported taxable income of $632,633 and total Federal income tax of $194,034. c. 2007 The Blakes filed a joint Federal income tax return for 2007. They did not report any income related to Mr. Blake's participation in the Sterling Plan, and they did no…
54. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
55. T.C. Memo. 1996-264 — Allan R. & Joan K. Powell v. Commissioner
    IRCCourt RulingsJun 11, 1996
    …o. 1995-93; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; see Wheeler v. Commissioner , T.C. Memo. 1993-561; see also Sites v. United States , 75 AFTR 2d 95-2503, 95-1 USTC par. 50,280 (D. Md. 1995). Thus, as a consequence of aggregating the Retirement System and the Pensi…
56. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002
    …tated in it. Lawinger v. Commissioner, 103 T.C. 428, 438 (1994); Wilkinson v. Commissioner, 71 T.C. 633, 639 (1979); Roberts v. Commissioner, 62 T.C. 834, 837 (1974). - 14 - G. Whether Petitioner Is Liable for the Accuracy-Related Penalty Under Section 6662 1. Adequate Disclosure and Reasonable Basis
57. T.C. Summary Opinion 2005-68 — Margret Louise Kelley v. Commissioner
    IRCCourt RulingsJun 2, 2005
    …ermined a deficiency in petitioner’s Federal income tax for the taxable year 2001 in the amount of $633. However, prior to trial, respondent filed a motion for leave to file answer out of time in order to assert an increased deficiency. See sec. 6214(a). Petitioner did not object to respondent’s motion, and the Court g…
58. 81 FR 21139 — Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Employee Be…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    75(e)(1) of the Code are included within the scope of relief provided by PTE 75-1 because it was issued jointly by the Department and the Service. See PTE 2002-13, 67 FR 9483 (March 1, 2002) (preamble discussion). For simplicity and consistency with the other new exemptions and amendments to other existing exemptions p…
59. 68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner
    IRCCourt RulingsSep 12, 1977related by meaning
    r, 68 T.C. 826 (1977). In view of concessions made by the parties and our conclusions on the disputed issues, Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated. Variances between this schedule and Form 4848 reflect persons …
60. 71 T.C. 32; 1 Employee Benefits Cas. (BNA) 2040 — Thompson v. Commissioner
    IRCCourt RulingsOct 12, 1978related by meaning
    levant documents comprising the application for determination. Such information was furnished to the Department of Labor by the IRS on April 20, 1977. On May 25, 1977, the Commissioner notified the trustees of Central that its plan, as amended effective January 30, 1976, was qualified, provided it adopted the additiona…