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90 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 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’ …
  2. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    ld require the inclusion of some amount, as a human capital investment, in determining the value of his personal services rendered to the corporation. For a variety of reasons, we decline to adopt such a rule. It is well settled that the individual identities of different taxable entities must be respected. Burnet v. C…
  3. T.C. Memo. 1998-30 — Brian J. Patrick v. Commissioner
    IRCCourt RulingsJan 26, 1998
    …Patrick--docket No. 26419-96 : Additions to Tax Sec. Sec. Year Deficiency 6651(a)(1) 6654 1992 $221,831 $55,458 $9,679 1993 11,647 2,912 488 1994 9,248 2,312 476 Brian J. Patrick--docket No. 26420-96 : Additions to Tax Sec. Sec. Year Deficiency 6651(a)(1) 6654 1992 $53,128 $13,157 $2,294 1993 5,701 1,425 239 1994 7,421…
  4. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971related by meaning
    g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
  5. 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…
  6. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner. Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
  7. T.C. Summary Opinion 2003-77 — Wallace W. Burke v. Commissioner
    IRCCourt RulingsJun 18, 2003related by meaning
    ly to assist taxpayers in filing tax returns; neither the Commissioner nor this Court is bound by such guidance where it is contrary to (continued...) taxpayer’s gross income generally are not part of the taxpayer’s investment in the contract, sec. 72(f). Therefore, in the context of this case, a taxpayer’s investment …
  8. T.C. Summary Opinion 2001-178 — Dennis J. Lawless v. Commissioner
    IRCCourt RulingsNov 28, 2001
    …C. 565, 568 (1954), affd. 231 F.2d 8 (5th Cir. 1956); Oilbelt Motor Co. v. Commissioner , 16 B.T.A. 831 (1929). The question here is whether a deficiency exists. Section 6211(a) defines the term “deficiency” as the amount by which the tax imposed exceeds the excess of: (1) the sum of–- (A) the amount shown as the tax b…
  9. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020
    …-90 (1975), aff'd per curiam, 540 F.2d 821 (5th Cir. 1976); Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965). A taxpayer claiming a deduction on a Federal income tax return must demonstrate that the deduction is allowable pursuant to a statutory
  10. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  11. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …r party's performance"), aM, 234 B.R. 691 (B.A.P. 6th Cir. 1999); Barrett v. Gilbertson, 827 N.W.2d 831, 840 (N.D. 2013) (holding that a contractor was excused from performance when homeowners refused to allow him onto the premises to repair alleged defects in the home's construction). 2See. e.g., Kader v. Paper Softwa…
  12. T.C. Memo. 2017-186 — Joe Pokawa & Nancy Fatoma v. Commissioner
    IRCCourt RulingsSep 21, 2017
    … 89-90 (1975), aß per curiam, 540 F.2d 821 (5th Cir. 1976); Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965); sec. 1.6001-1(a), (e), Income Tax Regs. -11- [*11] Section 162(a) allows a deduction for ordinary and necessary business expenses paid or incurred during the taxable year in carrying on any trade or busin…
  13. PLR 200818018 — Substantially Equal Payments
    IRCPrivate Letter RulingsMay 2, 2008related by meaning
    Internal Revenue Service Department of the Treasury Washington, DC 20224 Number: 200818018 Release Date: 5/2/2008 Index Number: 72.20-04 ------------------------------------------------------------ - --------------------------- ---------------------------------- ------------------------------------ Third Party Communic…
  14. 48 T.C. 75 — Pepsi-Cola Niagara Bottling Corp. v. Commissioner
    IRCCourt RulingsApr 26, 1967
    …2, and 1963, accrued contributions to the trust fund under the plan in the respective amounts of $5,831.13, $5,381.53, and $8,070.06, which amounts were actually paid by petitioner to the trust fund during the year subsequent to their accrual but within the time prescribed by law for filing the returns for the years of…
  15. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997
    … a method that clearly reflects income. Sec. 446(b); Meneguzzo v. - 8 - Commissioner , 43 T.C. 824, 831 (1965). When the Commissioner has evidence of taxable income but does not have information available to ascertain the amount of such income, the Commissioner may use BLS data to determine that the taxpayer had
  16. T.C. Memo. 1997-8 — Gary Benton & Karen Ruth Logsdon v. Commissioner
    IRCCourt RulingsJan 6, 1997
    …or redeposit, respectively) in the year in which they received their lump-sum credit. 5 C.F.R. sec. 831.2206 (1991). The CSRS reduced the lump-sum credits of the participants by the deemed deposit or redeposit but regarded the unreduced amount as taxable to the participants for Federal income tax purposes. Id. Petition…
  17. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006related by meaning
    f an intangible property right; (ii) the transfer of that intangible property right; or (iii) the securitization of the intangible property right. (4) Section 79.—Group-Term Life Insurance Purchased for Employees.—Whether a group insurance plan for 10 or more employees qualifies as group-term insurance, if the amount o…
  18. 41 T.C. 685 — Conroy v. Commissioner
    IRCCourt RulingsFeb 26, 1964
    …ey or the Public Health Service, or as a disability annuity payable under the provisions of section 831 of the Foreign Service Act of 1946, as amended (22 U.S.C. 1081; 60 Stat. 1021). SEC. 105. AMOUNTS RECEIVED UNDER ACCIDENT AND HEALTH PLANS.
  19. 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 …
  20. 157 T.C. No. 10 — Andrew McNulty & Donna McNulty v. Commissioner
    IRCCourt RulingsNov 18, 2021
    …c. 6057, 102 Stat. at 3698; Taxpayer Relief Act of 1997, Pub. L. No. 105-34, sec. 304, 111 Stat. at 831. Congress added the flush text in 1997 when it revised section 408(m )(3) to add subparagraph (B) to allow IRAs to invest in bullion. Statutory interpretation begins with the text of the statute, and we m ay consider…