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89 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  2. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Either party may move for summary adjudication upon all or any part of the legal issues in controversy. Rule 121(a). Full or partial summary judgment is appropriate where the record shows that there is no genuine issue as to any material fact and that a decisi…
  3. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    …he return. C rocker v. Commissioner , 92 T.C. 899 (1989); see also Berlin v. Commissioner , 59 F.2d 996 (2d Cir. 1932), affg. a Memorandum Opinion of this Court. To establish a proper estimate of th e tax liability for
  4. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
  5. 138 T.C. No. 20 — Shannon L. Fernandez v. Commissioner
    IRCCourt RulingsMay 14, 2012related by meaning
    etitioner does not cite any relevant law to establish her position. We similarly find none; and in the absence of congressional intent we note that we have strictly construed section 104(a)(1) to conform to the general purview of section 61, that all income is taxable unless explicitly excluded. See Baldwin v. Commissi…
  6. 115 T.C. No. 19 — Flahertys Arden Bowl, Inc. v. Commissioner
    IRCCourt RulingsSep 25, 2000related by meaning
    115 T.C. No. 19 UNITED STATES TAX COURT FLAHERTYS ARDEN BOWL, INC., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15223-98. Filed September 25, 2000. F owns more than 50 percent of the stock of P. F is a beneficiary of two retirement plans held by T. Under the terms of the plans F is authorized…
  7. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    r I.R.C. sec. 4973. He] : On the facts presented, Ps and not their Roth IRAs were the owners, for Federal tax purposes, of the FSC stock; in substance the FSC dividends were income to Ps, who contributed the funds to their Roth IRAs. Summa Holdings, Inc. v. Commissioner, 848 F.3d 779 (6th Cir. 2017), rev'g T.C. Memo. 2…
  8. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011
    …ck in a taxable transaction, or the corporation ceases to qualify as arDISC. Seca. 995(b) (2), (c), 996(a) (1). 3Petitioners cite Blue Bird Body Co. because they contend that Congress was aware of the issues raised therein. Petitioners cannot, and do not, cite the case for any precedential value because it was disposed…
  9. T.C. Memo. 1996-378 — Gaylord W. Greenlee v. Commissioner
    IRCCourt RulingsAug 15, 1996related by meaning
    c. Year 6651(a)(1) 1985 $ 813 1986 1,123 1987 1,403 1988 1,529 1989 1,581 1990 1,539 Then, in her reply brief, she conceded that the correct additions to tax are as stated in the text. The primary issue for decision is whether petitioner engaged in a prohibited transaction so as to be subject to the first-tier excise t…
  10. T.C. Memo. 2007-360 — Rodolfo & Bernadette Domingo v. Commissioner
    IRCCourt RulingsDec 5, 2007
    ….87 105,75 0 Both Domingos 931250798A 77,845 . 00 42 , 155 .00 120,00 0 Dr . Durante 931250795PR 21,996 .32 28 , 003 .68 50,00 0 Ms . Quinn 931250796PR 6,173 .67 5,826 .33 12,00 0 Total 587,75 0 Premiums were paid in the 2 years as follows : Insured Policy # 1993 199 4 Dr . DeAngelis 931250799PR $180,000 $178,62 5 Both…
  11. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
  12. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ding standard under section 412(d) but chose not to do so. We sustain respondent's determination of petitioner's section 4971(a) excise tax liability. FYE 1987 Employer ReversionSection 4980(a) imposes a 10-percent tax on the amount of any employer reversion from a qualified plan. The term "employer reversion" is defin…
  13. 106 T.C. No. 20 — Alfred E. Gallade v. Commissioner
    IRCCourt RulingsMay 28, 1996
    …. On or about January 15, 1986, the funds were withdrawn, including accrued interest (total of $772,996.44). GCI filed a second Form 5310 on or about March 5, 1986, to notify respondent and the PBGC of
  14. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …inion .- 25 ( . continue d traditional and Roth IRAs by modifying sec . 1361 .(c)(2)(A)(vi) See S . 996, 111th Cong' ., 1st Sess ., sec .-6(a) (2009) . The same proposal was introduced in .the Senate in each of the two preceding Congresses . See'S . 3063, 110th Cong ., 2d Sess ., sec . 6(a) (2008) ; S . 3838, . 109th C…
  15. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    ciency in excise tax under section 4973 on the basis of a determination that the taxpayers had made excess contri butions to their IRAs. The taxpayers urged that they had no excise tax liability because the IRS had not 6 See United States v. Skelly Oil Co. , 394 U.S. 678, 684 (1969); ATL & Sons Holdings, Inc. v. Commis…
  16. 109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner
    IRCCourt RulingsDec 29, 1997
    …his [purposes]" quoting C.G. Willis, Inc. v. Commissioner , 41 T.C. 468, 476 (1964), affd. 342 F.2d 996 (3d Cir. 1965), which involved nonrecognition of gain upon an involuntary conversion under section 1033. Petitioner also quotes a similar definition - 12 - of an involuntary conversion in Grant Oil Tool Co. v. United…
  17. T.C. Summary Opinion 2006-45 — Andrew J. & Ruthanne E. Eberly v. Commissioner
    IRCCourt RulingsMar 29, 2006
    …with - 5 - 1 As of that date, the balance of decedent’s TIAA-CREF accumulated annuity fund was $953,996. This balance does not take into account decedent’s $600,000 withdrawal request. the remaining 25 percent to be equally divided among three specifically identified charitable organizations. The Designation of Benefic…
  18. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    1 Cases of the following petitioners are consolidated herewith: David E. and Gladys A. Christie, docket No. 20363-94; and Dura-Craft, Inc., docket No. 20560-94. T.C. Memo. 1997-147 UNITED STATES TAX COURT MILO G. AND SARAH E. CHAPMAN, ET AL., 1 Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 20…
  19. T.C. Memo. 2018-49 — Stacey S. Marks v. Commissioner
    IRCCourt RulingsApr 10, 2018related by meaning
    bution out of an IRA that is then paid into another IRA owned by the same owner within 60 days. Id. Under section 408(e)(2)(A), if an IRA engages in a prohibited transaction, the account ceases to be an IRA as of the first day of the taxable year in which the prohibited transaction occurs. - 4 - [*4] Respondent's posit…
  20. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…