Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 85 T.C. 968 (not yet in the library — opens the official source)
78 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …pation in the Sterling Plan. For the respective years, this income was $188,797, $266,299, and $302,968 in the case of Mr. Abramo; $222,089, $304,978, and $346,515 in the case of Mr. Brown; and $199,454, $279,637, and $318,594 in the case of Mr. Tomassetti. We decide the following issues: 1. whether the life insurance …
  2. T.C. Summary Opinion 2002-33 — Wallace F. & Mi-Ja H. Smith v. Commissioner
    IRCCourt RulingsApr 3, 2002
    …percent adjusted gross income floor, as required by statute, the remaining amount of the loss, $292,968.65, was claimed on Schedule A, Itemized Deductions, as a casualty or theft loss deduction. Petitioners contend they sustained the casualty or theft loss as a result of the cancellation of petitioner's employersponsor…
  3. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    red all of petitioners’ arguments for contrary holdings; those arguments not discussed herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent necessary to reject or sustain each determination . We also have considered all of respondent’s arguments a…
  4. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024
    …43 $3,105,883 $2,836,896 Total Expenses 573,086 856,475 1,695,246 2,818,055 2,775,227 Net Income 56,968 5,863 295,397 287,828 61,669 For 2004, Special Agent Trogden examined the bank records of four bank accounts titled in the name of CMI Trust, over which petitioners had signature authority, and concluded that CMI Tru…
  5. IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
  6. 106 T.C. No. 20 — Alfred E. Gallade v. Commissioner
    IRCCourt RulingsMay 28, 1996
    …future costs and liabilities required to meet a plan’s funding. See Holland v. Valhi Inc. , 22 F.3d 968, 972
  7. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …3n the 2004 Form 1120S, Weekend Warrior reported a $1,626,198 deduction for designer costs and a $2,968,802 deduction for marketing services. During- the years at issue Weekend Warrior claimed depreciation deductions with respect to the airplane as follows: Year Special depreciation Depreciation Total depreciation 2002…
  8. U.S. Tax Court — Kathryn J. Gillette & Raif Szczepanski v. Commissioner
    IRCCourt RulingsNov 20, 2018
    …s side effects. Ms. Gillette and Mr. Szczepanski offered to compromise their 2012 liability for $38,968. The offer was forwarded to an offer examiner. The offer examiner reviewed Ms. Gillette and Mr. Szczepanski's financial information and determined that they had a reasonable collection potential of $813,484. During h…
  9. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    in language of the statute and, in effect, rewrite it in order to achieve what might be viewed by them as the more equitable result. See Hildebrand v. Commissioner , 683 F.2d 57, 58 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Zadan v. Commissioner , T.C. Memo. 1993-85. After all, the power to legislate is exclusively th…
  10. 60 T.C. 227; 60 T.C. No. 27 — Tobey v. Comm'r
    IRCCourt RulingsMay 17, 1973related by meaning
    …he Louvre in 1961; and the Commendeur d’ Order des Arts et des Lettres by the French Government In 1968. See. 911(b) provides as follows:
  11. T.C. Summary Opinion 2005-71 — Vincent A. Suarez, Jr. & Esther Suarez v. Commissioner
    IRCCourt RulingsJun 6, 2005related by meaning
    a matter of legislative grace, and the burden of clearly showing the right to the claimed deduction is on the taxpayer. INDOPCO, Inc. v. Commissioner , 503 U.S. 79, 84 (1992). We are bound by the Internal Revenue Code, and it is within the province of the legislature to decide the circumstances of inclusion, deductions…
  12. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996★ strong match
    … ultimately concedes or loses a case is not determinative. See Wasie v. Commissioner , 86 T.C. 962, 968-969 (1986); DeVenney v. Commissioner , 85 T.C. 927, 930 (1985). 2. Net Worth Respondent contends that petitioners have failed to demonstrate that they satisfied the net worth requirement of section 7430(c)(4)(A)(iii)…
  13. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
  14. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987related by meaning
    GOFFE, Judge: The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
  15. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    …41 17,685,562 18,698,759 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
  16. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    r's Life. Respondent further determined that petitioner is liable for the addition to tax under section 6651(a) for his failure to file a 1992 Federal income tax return. - 5 - OPINION Petitioner does not deny receipt of any of the items of income. Nor does he claim that any particular item of income has been overstated…
  17. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998related by meaning
    titioner, WE 7, and - 18 - 4 The complaint filed in the Superior Court indicates that the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987. the Guardian Construction Co., Inc., as corporate partners of Estes Co. Petitioner was identified as a partner…
  18. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  19. T.C. Memo. 2012-300 — Churchill, LTD. Employee Stock Ownership Plan & Trust v. Commissioner
    IRCCourt RulingsOct 25, 2012related by meaning
    hall include compensation which is not currently includible in the Participant's gross income by reason of the application of sections 125, 402(a)(8), 402(h)(1)(B), or 403(b) of the Code, but shall not exceed $200,000 for any Plan Year. -15- [*15] In the second amendment to the 1989 plan the definition of "compensation…
  20. 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…