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41. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002related by meaning
    (c)(2). Thus, we sustain respondent’s determination on this issue. C. Petitioner’s IRA Deductions As a preliminary matter, we note that deductions are strictly a matter of legislative grace, and a taxpayer bears the burden of proving his or her entitlement to the claimed deductions. 18 Rule 142(a)(1); see New Colonial …
42. 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…
43. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
44. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    g the term "employer reversion" subsection (c) begins with the words "For purposes of this section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for purposes of the income tax . Indeed this Court has so indicated. Lee Engineering Supply Co. v. Commissione…