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41. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …y dividends to IRA #1. 3 Commissions paid to - 6 - 3 (...continued) 12/30/88 12/31 88 122,352 Total 593,602 No distributions were made to petitioners from the trust during
42. T.C. Memo. 2006-47 — Diep N. Hoang v. Commissioner
    IRCCourt RulingsMar 20, 2006
    …substantiated testimony. See Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964). The Court need not accept at face value a witness's testimony that is self-interested or otherwise questionable. See Archer v. Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg. a Memorandum Opinion of th…
43. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    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…
44. T.C. Summary Opinion 2005-114 — Francis N. & Patricia A. Leonard v. Commissioner
    IRCCourt RulingsAug 4, 2005
    … or by normal depreciation. Maher v. Commissioner , 680 F.2d 91, 92 (11th Cir. 1982), affg. 76 T.C. 593 (1981); Coleman v. Commissioner , 76 T.C. 580, 589 (1981). There must be a causal connection between the alleged casualty and the loss claimed by the taxpayer. Kemper v. Commissioner , 30 T.C. 546, 549-550 (1958), af…
45. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
46. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    … 60 (1929); cf. Long Island Drug Co. v. Commissioner, 35 B.T.A. 328, 333-334 (1937), affd. 111 F.2d 593 (2d Cir. 1940), cert. denied 311 U.S. 680 (1940).
47. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
48. T.C. Memo. 2005-67 — Laura D. Seidel v. Commissioner
    IRCCourt RulingsMar 31, 2005
    … Special Trial Judge : Respondent determined a deficiency in petitioner’s Federal income tax of $24,593 and an additional tax of $4,397.87 pursuant to section 72(t) for the taxable year 1999. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the - 2 - year in issue, and all R…
49. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
50. T.C. Memo. 2025-1 — Matthew D. Hutcheson & Annette Hutcheson v. Commissioner
    IRCCourt RulingsJan 2, 2025
    …h the requisite fraudulent intent. See Holmes v. Commissioner, T.C. Memo. 2012-251, at *31, aff’d , 593 F. App’x 693 (9 th C ir. 2015). The following badges of fraud are present in this case . Mr. Hutcheson under reported his income by over $5.3 million , gave
51. 98 T.C. 503; 98 T.C. No. 34 — Fowler v. Commissioner
    IRCCourt RulingsApr 22, 1992related by meaning
    tatutoiy references are to the Internal Revenue Code in effect for 1986, and all Rule references are to the Tax Court Rules of Practice and Procedure. he parties have stipulated as follows: 8. During 1986, the petitioner, due to his termination of employment * * * received a total distribution from his employer's Incen…
52. 68 T.C. 433 — Newman v. Commissioner
    IRCCourt RulingsJun 29, 1977
    …alidity attaching to the statute as so construed. See Estate of Klein v. Commissioner, 63 T.C. 585, 593-595 (1975), affd. 537 F.2d 701 (2d Cir. 1976), cert. denied 429 U.S. 980 (1976).
53. 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…
54. T.C. Memo. 2002-166 — Wayne A. McFadden v. Commissioner
    IRCCourt RulingsJul 2, 2002
    …orn v. Commissioner , T.C. Memo. 1998-377 (citing Am. Offshore, Inc. v. Commissioner , 97 T.C. 579, 593-594 (1991)), affd. 205 F.3d 1345 (8th Cir. 1999). Petitioner must establish sufficient objective facts from which worthlessness could be determined. Fox v. Commissioner , 50 T.C. 813, 822-823 (1968), affd. per curiam…
55. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
56. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    f section 6501, 1 section 6651(a)(1), 2 - 37 - 2 (...continued) (2003) ; Janpol v. Commissioner , 102 T.C. 499, 503, 505 (1994); Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, aff…
57. T.C. Memo. 1999-174 — Chrys L. Udoh v. Commissioner
    IRCCourt RulingsMay 21, 1999
    …penses: Beeper, phone $849 Subscriptions & law books 974 Clothing, shoes & maintenance 728 Seminars 593 Continuous legal education & examination fees 1,935 5,079 Total 14,897 Schedule C: "Clothing And Accessories" Cost of goods sold $3,128 Expenses: Advertising 455 Supplies 826 Taxes & licenses 312 Other expenses: Tran…
58. 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’ …
59. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014
    …e record redound to petitioners' detriment. See Rule 122(b); Woodsum v. Commissioner, 136 T.C. 585, 593, 594, 596 (2011) (in a fully stipulated case submitted under Rule 122 involving liability for the accuracy-related penalty, gaps in the 3 We note that apart from the legal issue presented herein, petitioners do not d…
60. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…