IRCCourt RulingsAug 12, 1980related by meaning
nstant case — to avoid the section 4973 excise tax.
We hold that Johnson is liable for the asserted excise taxes under section 4973 for 1975 and 1976. It appears that the notice of deficiency addressed to petitioners may be understood as asserting joint liabilities for the excise tax deficiencies. (See n.l supra) Since…
IRCCourt RulingsDec 5, 2007
… in
October 2000 was converted to participating reduced paid-up
insurance with a face value of $669,547 .
18 APL provisions allow an insurance company to pay a
premium due on a policy by way of a loan taken out against the
cash value of the policy . The loan is subject to interest
charges and affects the policy's cash …
IRCCourt RulingsMar 12, 2015
… or employee. See McMahan v. Commissioner,
114 F.3d 366, 369 (2d Cir. 1997), afff'g T.C. Memo. 1995-547.
Petitioner was required to file a return for 2009, e supra part II, and failed
to do so. Accordingly, respondent has carried his burden of producing evidence
showing that the addition to tax under section 6651(a)(1)…
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows:
Deficiencies in—
Docket No. Petitioners Income tax gi
6173-77 John L. Guest .$437.60
9115-77 James Ventresca and Jordy L. Ventresca . 296.00
Jerome Kobos . 286.18
Edward And…
IRCCourt RulingsJul 22, 1999
… resided in Yakima, Washington.
In 1993, 1994, and 1995, Mr. Morin earned $50,712, $55,118,
and $32,547, respectively, from Les Morin Subaru as compensation
for his services. In 1993 and 1995, Mr. Morin received prizes
from Subaru of America, Inc., in the amounts of $650 and $625,
respectively.
In 1994, Mr. Morin recei…
IRCCourt RulingsOct 16, 2017related by meaning
T.C. Memo. 2017-201
PA
UNITED STATES TAX COURT
JOSEPH E. BORMET, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6863-16. Filed October 16, 2017.
Bradley S. McCann, for petitioner.
Angela B. Reynolds and Briseyda Villalpando, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: Respondent determined a…
IRCCourt RulingsJun 7, 1984related by meaning
eived. An exception is provided in § 402(a)(2) for capital gains treatment in specific cases. * * * The exception was always strictly construed. * * * Further expansion of the favored treatment specifically provided in § 402(a)(2) as an exercise of legislative grace is a function for the Congress, not for the Courts. S…
IRCCourt RulingsDec 18, 2012related by meaning
hat the 10% additional tax under section 72(t) applies) to
the extent stated;
6. whether petitioners may deduct itemized deductions in amounts greater than respondent allowed (which was zero for each year). We hold that they may
not; and
7. whether petitioners are liable for the additions to tax under sections
6651(a) …
IRCCourt RulingsMar 11, 2020related by meaning
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…
IRCCourt RulingsFeb 22, 1999related by meaning
lating to petitioners' loan,
10.5 percent is the fair market interest rate.
V. Addition to Tax
Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to
file Form 5330 for each taxable year, or portion thereof, in the
taxable period. Sec. 6011; sec. 54.6011-1(…
IRCCourt RulingsOct 1, 2025
…22. This discrepancy is
minor and does not affect the resolution of this case.
9
[* 9 ] totaling $2,547,815 , net monthly income of $9,487,
6
and an amount
that could be paid, also known as a reasonable collection potential
(RCP ), of $2,661,659. The In itial Offer was sent back to AO Alves , and
the CDP case was broug…
IRCCourt RulingsJul 30, 2007
…nsurance Contracts, etc ., reporting that petitioner received
$4,687 from MBNA Corp . 401K and had $547 of Federal income tax
withheld ; and (3) a letter which stated "he had no `income' in a
`constitutional sense' as the word `income' is used in Section 61
of the Internal Revenue Code" and other frivolous tax-proteste…
IRCCourt RulingsJun 9, 1965
…tal
Common stock — $10 par value; authorized 100,000 shares; issued and outstanding 54,750 shares.. 547, 500. 00
Retained earnings_ 971, 132. 21
- 1, 518, 632. 21
Total liabilities and capital. 1, 767, 068. 18
IRCCourt RulingsMay 20, 1976related by meaning
ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment.
SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
IRCCourt RulingsSep 30, 2003related by meaning
ance with its substance.”
Neonatology Associates, P.A. v. Commissioner
, 299 F.3d 221, 230
n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is
free to organize his affairs as he chooses, nevertheless, once
having done so, he must accept the tax co…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsJan 3, 2011related by meaning
s, earnings, and reasonable charges) pursuant
tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not :
rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant
to Rev. Proc . 2005-25, lsupra.
Held, further, P must include in his gross income
the excess contributiorls pursuan…
IRCCourt RulingsOct 9, 2007related by meaning
ers . In response to
our leniency, petitioner once again ignored our Rules and our
order .
-5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a
sanction pursuant to Rule 123(b) . See Stringer v . Commissioner ,
84 T .C . 693, 704-705 (1985), affd . withou…
IRCCourt RulingsDec 8, 1987
…F.2d 1036, 1039 (5th Cir. 1978); In re Kline, 403 F. Supp. 974, 979 (D. Md. 1975), affd. per curiam 547 F.2d 823 (4th Cir. 1977).
IRCCourt RulingsOct 10, 1979related by meaning
Tannenwald, Judge:
Respondent determined deficiencies in the Federal income tax of petitioner for 1971, 1972, and 1973 in the respective amounts of $3,576.58, $4,052.04, and $3,912 together with negligence penalties under section 6653(a). The negligence penalties have been conceded by respondent, and capital loss adjus…