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41. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …95 Salaries & wages 148,750 29,167 200,565 303,750 Pension, profit-sharing, plans 46,907 25,000 132,428 169,170 Employee benefit programs -0- -0- -0- -0- Other deductions (VEBA contribution) 480,901 -0- 209,869 296,056 Taxable income (loss) 3,664 (103,857) (23,325) (7,796) Income tax 1,246 -0- -0- -0- Alt. minimum tax …
42. 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…
43. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …ees-0 - - 0-173,550 79,263 128,000 Exemption 100 100 100 100 100 Taxable Income 164,781 199,276 (20,428) (22,898)(182,687) Total tax 46,139 61,017-0 - - 0 - - 0 - The Trust paid no benefits in 1988. From 1989 through 1994, the Trust paid $30,420,770 in employer withdrawal benefits and DWB's as shown below: 1989 1990 19…
44. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    in the - 11 - (...continued) 2085, 2481-2483. It was subsequently renumbered by sec. 1011A(g)(1)(A) of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3479. Because the applicable regulation does not reflect the statutory renumbering, the regulation appears as sec. 54.4981A-1T, Te…
45. T.C. Summary Opinion 2001-182 — Roy Robert Botts v. Commissioner
    IRCCourt RulingsDec 11, 2001
    …ssed at trial). On or about May 12, 1997, Union Bank issued petitioner a check in the amount of $33,428.29. The amount of the check reflected the 401(k) distribution of $55,404.63 less the
46. T.C. Summary Opinion 2006-11 — Richard Bradley v. Commissioner
    IRCCourt RulingsJan 26, 2006
    …h Cir. 1962), affg. in part and revg. in part 32 T.C. 998 (1959); Zuanich v. Commissioner , 77 T.C. 428, 432-433 (1981). An exception exists only in the rare case where a taxpayer can prove he or she would suffer an unconscionable injury because of that reliance. Manocchio v. Commissioner , 78 T.C. 989, 1001 (1982), af…
47. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
48. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    983). They are among the clearest and most central requirements for favorable tax treatment and cannot be disregarded — deliberately or inadvertently. The amounts in question here ($80,490 and $6,715) were not de minimis, and in a quantitative sense they were material. The error occurred in more than one year, and occu…
49. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998
    …nd additions to tax as follows: Additions to Tax Sec. Sec. Year Deficiency 6651(a)(1) 6654 1993 $37,428 $6,397 $1,017 1994 41,918 8,829 1,782 Petitioner petitioned the Court on December 30, 1996, to redetermine respondent's determination of these deficiencies and additions to tax. We must decide: (1) Whether petitioner…
50. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468. Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
51. 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…
52. T.C. Summary Opinion 2014-50 — Joel G. Nganga v. Commissioner
    IRCCourt RulingsJun 4, 2014
    …fit or Loss From Business, for 2010 or (2) that he received a taxable State income tax refund of $5,428 in 2011. Accordingly, petitioner is deemed to have conceded those issues. See Rule 34(b)(4) ("Any issue not raised in the assignments of error shall be deemed to be conceded."); see also McNeil v. Commissioner, T.C. …
53. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
54. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988related by meaning
    e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted. An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
55. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …enalties Year Deficiency Sec. 6662(a) Sec. 6662A 2005 $276,032 $55,206 -02006 402,643 80,529 -02007 428,303 -0- $85,660 Netversity, Inc., docket No. 11520-11 Accuracy-related penalty Year Deficiency Sec. 6662(a) 2006 $9,872 $1,974 2(...continued) dollar. We interchangeably use the terms "insurance contract" and "insura…
56. T.C. Summary Opinion 2003-153 — Joseph Jones v. Commissioner
    IRCCourt RulingsOct 20, 2003related by meaning
    result apparently so at odds with accepted tax policy.” Darby v. Commissioner , supra at 68. We find that petitioner did not have a basis in the 1999 distribution from his section 401(k) plan, and that petitioner properly included the full distribution in his 1999 gross income. Accordingly, we hold that petitioner is l…
57. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    …ted by the legislators. Barr v. United States, 324 U.S. 83 (1945); Zuanich v. Commissioner, 77 T.C. 428 (1981); Rechner v. Commissioner, 30 T.C. 186 (1958). Unless indicated otherwise, all Rule references are to the Tax Court Rules of Practice & Procedure. SEC. 61. GROSS INCOME DEFINED. (a) General Definition. — Except…
58. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …t of 1958 , Pub . L . 85-866, sec . 64, 72 Stat . 1650 . 28 Revenue Rulings 65-9 .0, 1965-1 C . B . 428, and 66-266, 1966-2 C .B . 356 . 29 Employee Retirement Income Security Act of 1974, Pub . L . 93-406,,sec . 2002(b), 88 Stat . 959 . Sept . 2, 1974 .
59. 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 …
60. 124 T.C. No. 12 — Charles P. Stepnowski v. Commissioner
    IRCCourt RulingsApr 26, 2005
    …nt value of a participant's accrued benefit. See Myers-Garrison v. Johnson & Johnson, 210 F.3d 425, 428 (5th Cir. 2000). Because the use of a higher discount rate results in a lower present value for a participant's accrued benefit, the question that