IRCCourt RulingsJan 22, 2025
… 180, 183 – 84 (1957); Schuster v.
Commissioner, 800 F.2d 672, 676 (7th Ci r . 1986), aff’g 84 T.C. 764
( 1985) ; see also ATL & Sons Holding s , Inc. v. Commissioner , 152 T.C.
138, 147 (2019) (citing United States v. Skelly Oil Co. , 394 U.S. 678, 684
IRCCourt RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
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To reflect the foregoing,
An appropriate order of
dismissal a…
IRCCourt RulingsJan 12, 1998
… and Gail H. Rush 8,706
6617-96 Alice M. Johnson
1
7,397
6761-96 Robert J. and Bette Barraclough 10,764
7632-96 William N. and Joan E. Hughes 128,225
9362-96 William W. and Joan E. Agnew 46,533
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9490-96 Joe O. and Daurine M. Baker 3,002
15341-96 Joseph P. and Genice Spetz 8,724
15342-96 Robert C. and Mary D. Borma…
T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner IRCCourt RulingsMar 5, 2007
…tioner not be granted relief under
section 6015(f), the Appeals officer said that petitioner had
$1,764 of disposable income per month in 2001, and that her
income had increased since then. That amount roughly equals the
excess of petitioner’s monthly income (including child support)
in 2001 of $4,184 over the six mont…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
IRCCourt RulingsApr 15, 2002
…Taxes and licenses 20
Travel 6,768
Meals and entertainment
2
1,527
Utilities 120
Other expenses
3
3,764
Total expenses 13,102
Tentative loss (12,732)
Net loss
4
--
1
All of the reported gross income derived from petitioner’s
handyman activity.
2
Petitioners reported meals and entertainment expenses of
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$3,054 but,…
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
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[…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…6 513,695 35,861,031 (1,564,606)
6/30/84 65,700,275 702,776 66,403,051 2,409,636
6/30/85 72,255,521 764,275 73,019,796 (50,720)
6/30/86 81,916,703 829,481 82,746,184 1,752,870
6/30/87 94,305,548 962,317 95,267,865 4,098,466
6/30/88 112,993,217 1,725,585 114,718,802 6,871,287
6/30/89 143,612,396 4,476,187 147,088,583 9,…
IRCCourt RulingsOct 2, 1974related by meaning
C. 1005, 1011-1013 (1972), affirmed per order (C.A. 1, Apr. 26, 1973). Petitioners have not shown that BG timely paid the disputed funds to the trust. Petitioners urge us to expand or modify the terms “paid” or “payment,” holding that substantial compliance with the statute is sufficient in order to avoid denial of a d…
IRCCourt RulingsFeb 9, 2023
…provide, for the first time, a definition of the very term
that the regulation interpreted. Id. a t 764, 766. Accordingly, the reasons for amending
the regulation were to some extent self-evident: There had been a statutory reset. As
described in Part II below, the addition of the second sentence to section 482 is not
…
IRCCourt RulingsJun 29, 2015
…r of Summa (or in the
alternative, that he received $519,002 and the Benenson Trust received $1,702,764
in dividends from Summa on the basis of their respective ownership interests in
Summa); and (3) determined that Summa's shareholders contributed $1,119,503 to
each of the Benenson Roth IRAs. Since the contributions t…
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…
IRCCourt RulingsJul 5, 2011
…cepted the fair market values
as acáurate and correct.
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As of Dec. 31 Fair Market Value
2002 $764,200
2003 919,173 0
2004 991,675
2005 1,245,804
2006 1,037,275
Mr. Paschall asserts that the excise tax should be based on
the $2,000 he used to initially fund the Baum Roth IRA and which
was contributed to Telesis wh…
IRCCourt RulingsJan 31, 1973
…rred by the end of its fiscal years, the amounts are properly deductible. Lukens Steel Co., 52 T.C. 764 (1969), affd. 442 F. 2d 1131 (C.A. 3, 1971). Respondent argues, however, that these amounts were in fact deferred compensation within the meaning of section 404 and therefore not deductible until actually paid. Petit…
IRCCourt RulingsOct 19, 2010related by meaning
tter of local law and a
State court's determination with regards to such assignment is
not reviewable by this Court);9 Chambers v. Commissioner, supra 9This Court recognizes that in Commissioner v. Estate of
Bosch, 387 U.S. 456, 465 (1967), the Court held that where the
Federal estate tax liability turns upon the chara…
IRCCourt RulingsJul 22, 1980
…401-l(b), Income Tax Regs.; South Texas Commercial National Bank of Houston v. Commissioner, 7 T.C. 764 (1946), affd. 162 F.2d 462 (5th Cir. 1947). The “Engineered Timber Sales, Inc. Profit-Sharing Trust” executed on December 30, 1974, provides for establishment of a trust fund, trust administration, investment of fund…
IRCCourt RulingsAug 22, 1994
…8,698,759
Other disbursements -0- 50,000 1,736,964
Total disbursements 29,309,726 34,968,999 36,063,764
Net increase (decrease) of assets 5,552,678 1,895,497 6,886,506
Assets at end of period 5,552,678 7,448,175 14,334,681
Reserves for Incurred But Unpaid Claims
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsFeb 6, 1992related by meaning
n is subject to section 404. It is difficult, if not impossible, to discuss deferring receipt of compensation without focusing on the time of payment. We also reject petitioner's contention that the case at hand is similar to that in Minahan v. Commissioner, 88 T.C. 492 (1987). We held, in that case, that the Secretary…
72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner IRCCourt RulingsJun 11, 1979
…atrobe Steel Co. v. Commissioner, 62 T.C. 456 (1974); and Lukens Steel Co. v. Commissioner, 52 T.C. 764 (1969), affd. 442 F.2d 1131 (3d Cir. 1971), relied upon by petitioner, the employee benefit plans were instituted as a result of arm’s-length bargaining between unions and the employer. As a result of that bargain, t…