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90 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 114 T.C. No. 17 — Michael G. Bunney v. Commissioner
    IRCCourt RulingsApr 10, 2000
    …e sole contributor and the sole distributee of IRA funds. In Powell v. Commissioner , 101 T.C. 489, 496 (1993), we indicated that the distribution of a community property interest - 10 - in a retirement plan is taxed one-half to each spouse except where Congress has specified otherwise; e.g., in sections 219(f)(2), 402…
  2. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
  3. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011
    …ance, protection. Pétitioner contends that the fair market value of the cost of lif insurance is $8,496; i.e., the 2004 mortality charges3 ResponÈl.ent contends that the value of the life insurance protecNon is $13,510; i.e., -the annual cost, according to Not ice 2001-10, Table,2001, 2001;-1 C.B. 459, 463, for $1 mi-l…
  4. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    4, 2011, but was continued on petitioners' motion so that the parties could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on petitioners' motion so that they could take a trip out of the country. By notice served May 9, 201…
  5. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  6. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  7. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
    IRCCourt RulingsAug 13, 1999
    …ts normalcy in - 12 - the particular business are controlling. See Deputy v. DuPont , 308 U.S. 488, 496 (1940). Necessary connotes a sense that the expense is appropriate and helpful, rather than absolutely essential. See Welch v. Helvering , supra at 113. Petitioner maintained the plan as compensation for its employee…
  8. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
  9. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997★ strong match
    …nment in some circumstances, there is no basis for applying the concept here. Cf. OPM v. Richmond , 496 U.S. 414, 420 (1990). The traditional elements of estoppel are: (1) Misrepresentation by the party against whom estoppel is asserted; (2) reasonable
  10. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …. sec. 5302(a) and (b) (2012); Intelligence Authorization Act for Fiscal Year 1993, Pub. L. No. 102-496, sec. 265, 106 Stat. at 3237-3238 (codified at 50 U.S.C. sec. 2095 (2012)); Social Security Amendments of 1967, Pub. L. No. 90-248, sec. 152(b), 81 Stat. at 861 (codified as amended at 42 U.S.C. sec. 404(b) (2012 & S…
  11. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    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 …
  12. T.C. Memo. 2005-5 — Thomas G. Wright and Estate of Rosemary K. Wright, Deceased; Thomas G. Wright, Personal Representative v. Commissioner
    IRCCourt RulingsJan 13, 2005
    …hat the Government may not be estopped “on the same terms as any other litigant.” OPM v. Richmond , 496 U.S. 414, 419 (1990); Heckler v. Cmty. Health Servs. , 467 U.S. 51, 60 (1984). Equitable estoppel is applied “against the Government with utmost caution and restraint”. Schuster v. Commissioner , 312 F.2d 311, 317 (9…
  13. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    but did not." Central Tablet Manufacturing Co. v. United States , 417 U.S. 673, 690 (1974); Commissioner v. National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149 (1974). It would be quite intolerable to pyramid the existing complexities of tax law by a rule that the tax shall be that resulting from the for…
  14. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981
    …me and his office, and the expenses thereof are not deductible. Steinhort v. Commissioner, 335 F.2d 496, 503 (5th Cir. 1964), affg. on this issue a Memorandum Opinion of this Court; Foote v. Commissioner, 67 T.C. 1, 6 (1976).
  15. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    …ical Distrib s ., Inc. v. Commissioner , 105 F.3d 322, 326 (6th Cir. 1997) , aff’g T.C. Memo. 1995- 496. And we defer to the agency’s interpretation unless it is “arbitrary, capricious, or manifestly contrary to the statute.” Chevron , 467 U.S. at 843– 44; see also Mayo Found. for Med. Educ. & Rsch. v. United States, 5…
  16. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007related by meaning
    s were attributable to disability, or that the distributions otherwise qualify for an exception to the 10-percent additional tax. In fact, petitioners state on brief that "Petitioners do understand that petitioners have to pay 10% penalty tax on the amount stated above * * * This is consistent with IRC section 72(t) (1…
  17. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …nd plainly inconsistent with the revenue statutes". Commissioner v. South Tex. Lumber Co., 333 U.S. 496, 501 (1948). The regulations under section 72 are not unreasonable and are not plainly inconsistent with the statute with respect to the issue presented in the instant case. The regulations promulgated under section …
  18. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  19. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997
    … Electric & Neon, Inc. v. Commissioner , 56 T.C. 1324, 1340 (1971), affd. without published opinion 496 F.2d 876 (5th Cir. 1974); sec. 1.162-7(a), Income Tax Regs. Whether the taxpayer has shown the requisite intent to treat the payments as compensation is a factual question to be decided on the basis of the particular…
  20. 115 T.C. No. 19 — Flahertys Arden Bowl, Inc. v. Commissioner
    IRCCourt RulingsSep 25, 2000related by meaning
    lity for the excise taxes and that petitioner was liable for the additions to tax under section 6651(a)(1). Discussion I. Liability Under Section 4975 A. The Statutes Section 4975 was added to the Internal Revenue Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003…