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41. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986★ strong match
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
42. PLR 201540015 — Deduction for Certain Foreign Deferred Compensation Plans
    IRCPrivate Letter RulingsOct 2, 2015
    … to the pension plans. The taxpayer corporation failed to make a timely contribution to the plan in 1957 and was, therefore, unable to claim a deduction for any amount under section 404(a)(1) of the Code for 1957. The taxpayer corporation contended that it should be allo wed to include the cost PLR - T - 103529-15 4 ba…
43. 37 T.C. 7 — Barbourville Brick Co. v. Commissioner
    IRCCourt RulingsOct 9, 1961
    … stockholders of $99,247.81 and $6,125.16 during the years ended December 31, 1956, and October 15, 1957, respectively. Petitioner was completely liquidated by October 1957. The amount of $5,100 was recorded on petitioner’s books and records as an expense for its taxable year 1954 and was claimed as a deduction on its …
44. T.C. Summary Opinion 2004-29 — Howard T. Owens, Jr. & Ann E. Owens v. Commissioner
    IRCCourt RulingsMar 15, 2004related by meaning
    tutory scheme itself suggests that other liberties should not be indiscriminately inserted through the judicial process. Cf. Larotonda v. Commissioner , 89 T.C. 287 (1987) (interpreting former section 72(m)(5), a penalty provision without the list now contained in section 72(t)(2), and largely limited to its facts by o…
45. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
46. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
47. 124 T.C. No. 12 — Charles P. Stepnowski v. Commissioner
    IRCCourt RulingsApr 26, 2005related by meaning
    …ns and to fashion equitable remedies tö resolve these controversies." Simmons v. Commissioner, T.C. Memo. 1995-422; see also Stevens v. Commissioner, T.C. Memo. 1985-192; Wenzel v. Commissioner, T.C. Memo. 1982-595, affd. 707 F.2d 694 (2d Cir. 1983). Rather, in a declaratory judgment action under section 7476, we must …
48. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    ng warned by the Court and after having received notice from the Court in a prior case. 6 On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's position is both frivolous and groundless. Accordingly, we exercise our discretion and award a penalty t…
49. 39 T.C. 665 — Waller v. Commissioner
    IRCCourt RulingsJan 16, 1963
    …nowledged on November 3, 1955, but was never ruled upon by the Internal Revenue Service. On May 10, 1957, the petitioners appointed the Nashville Bank & Trust Co. of Nashville, Tenn., as an additional trustee to handle the investments of the Fund. On May 31,1957, the petitioners, as settlors and trustees, and the bank …
50. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
51. 40 T.C. 7 — Heard v. Commissioner
    IRCCourt RulingsApr 10, 1963
    … military service. From May 1956, when petitioner’s annuity payments commenced, through December 31,1957, petitioner received civil service retirement benefits totaling $3,620. On December 31, 1957, petitioner had recovered as benefits all of the retirement deductions withheld from his salary, except $19.01. Petitioner…
52. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    …ollowing items: (1) Compensation for services, including fees, commissions, and similar items; T.C. Memo. 1983-659. Respondent concedes, for purposes of the instant case, that the plan (whether the Judicial Plan or the System’s Plan) satisfies the requirements of paragraphs (1), (3), (4), and (5) of sec. 457(b). See R.…
53. 44 T.C. 623 — Leavens v. Commissioner
    IRCCourt RulingsJul 23, 1965
    …s to tax under sec. 6651(a) I.R.C. 1954 William B. and Emeline Leavens, Jr. 1956 2103-63 $18,007.95 1957 791-63 23,469.63 1958 791-63 27, Oil. 67 1959 791-63 45,817.09 Robert C. and Mae C. Glass. 1956 964-63 10,286.93 1957 964-63 13,348.04 1958 964-63 15,713.89 1959 964-63 28,002.67 John and Marie Last. 1956 1189-63 6,…
54. T.C. Memo. 2017-125 — Jeremy Ray Summers v. Commissioner
    IRCCourt RulingsJun 26, 2017related by meaning
    e requirements of the QDRO provisions must be "rigidly observed" because they "relate to the substance or essence of the statute"). We have con- - 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help minimize stress on his soon-to-be ex-wife disabled him from satisfying the statutor…
55. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    n. - 15 - To give effect to our disposition of the disputed issue, as well as petitioner's concession, see sap_rg note 2, Decision will be entered for respondent as to the income tax deficiency and for petitioner as to the accuracy-related penalty.
56. 40 T.C. 1018 — Van Products, Inc. v. Commissioner
    IRCCourt RulingsSep 24, 1963
    …ng., 1st Sess., pp. 21-22, 72t-73, accompanying H.R. 8381, known as the Technical Amendments Act of 1957, which was passed by the House but not by the Senate in 1957, and which in substance, to the extent material here, was enacted the following year as the Technical Amendments Act of 1958. See S. Rept. No. 1983, 85th …
57. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    was the only exception intended by Congress, since, had it intended any other, it would similarly have been specifically stated in the Code. We agree. Substantially the same argument made by petitioners was made and rejected in Sullivan v. Commissioner, 76 T.C. 1156 (1981), affd. by unpublished order (10th Cir. 1983). …
58. I.R.C. § 501(c)(14)(A) — Exemption from tax on corporations, certain trusts, etc.
    IRCCode / StatuteJan 24, 2020
    …it. (c)(14)(B) (B) Corporations or associations without capital stock organized before September 1, 1957, and operated for mutual purposes and without profit for the purpose of providing reserve funds for, and insurance of shares or deposits in— (c)(14)(B)(i) (i) domestic building and loan associations, (c)(14)(B)(ii) …
59. T.C. Memo. 2011-2 — Michael C. Hollen, D.D.S., P.C. v. Commissioner
    IRCCourt RulingsJan 4, 2011related by meaning
    …l tax- treatment-under section 501(a). See generally Ronald R. Pawlak, P-.C. v. ,Commissioner, T.C. Memo. 1995-7 (discussing the types of preferential tax treatment:under section 501(a)). In addition, 'the Employee Retirement Income Security Act of 1974, Pub. L. 93-406,- sec. 402(a) (1) 88 Stat. 875; requires that the …
60. 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…