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41. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8 (2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on the date which is 60 days after the later of . . . [the] earliest incident date . . …
42. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016
    …e, or amount of any omitted income. We conclude that a reasonable person would not discern from the 2003 joint return that petitioners had omitted any gross income for 2003, and we hold that the six-year limitations period under section 6501(e) applies. See Estate of Fry v. Commissioner, 88 T.C. at 1023. As to petition…
43. T.C. Memo. 2010-20 — Gregory A. & Carolyn S. Prough v. Commissioner
    IRCCourt RulingsFeb 3, 2010
    ), 2002- 2 C .B . at .711 ; Rev . Rul . . 2003-60, 2003-1 C .B . 987, 988 ; Rev . .Rul . 2003-71, 2003-2 C .B . 1, 2 . Petitioners also claim that the distributions were calculated so as to continue over petitioner's lifetime without depleting the account . Petitioners have not, provided any documentation or testimony …
44. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
45. 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…
46. T.C. Memo. 2010-61 — Wendy W. Bozick v. Commissioner
    IRCCourt RulingsMar 30, 2010
    … Cir .''2004) . . It is uncontested that Bozick satisfies the .threshold conditions of Rev . Proc . 2003-61, sec . 4 .01, 2003-2 C .B . 296, 297-298 . But Bozick fails to qualify,for relief under Rev . Proc . 2003-61, sec . 4 .02, 2003-2 C .B . at 298, because, as we explain later, Bozick had reason to know the 2003 li…
47. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008related by meaning
    …er’s determination of a deficiency in her 1993 and 1994 taxes. She lost, for reasons explained in a summary opinion. The Commissioner came to collect, and she demanded a collection due process hearing. The Commissioner argued that she was barred from again challenging her underlying liability at the hearing, but she th…
48. T.D. 9081 — REG-129709-03 Temporary and proposed regulations under section 409(p) of the Code provide guidance concerning the requirements for employee stock ownership pla…
    IRCTreasury DecisionsSep 2, 2003
    …bchapter S corporations. A public hearing on the proposed regulations is scheduled for November 20, 2003. REG-108639-99 REG-108639-99 Proposed regulations under sections 401(k) and 401(m) of the Code provide guidance on the requirements for certain retirement plans containing cash or deferred arrangements and providing…
49. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025related by meaning
    Treas. Reg. § 1.482-7T(i)(6) does not operate as a safe harbor and therefore does not preclude R from making a PCT allocation under paragraph (i)(3). 6. Held, further, R did not abuse his discretion under I.R.C. § 482 by adjusting P’s and S’s RAB shares to determine the required CST p ayment. 7. Held, further, R ’s me…
50. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025related by meaning
    …matter of law . See Rule 121(a)(2); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant summary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party. Sundstrand Corp. , 98 T.C. at 520. The nonmoving party may not rest upon mere allegations…
51. T.C. Summary Opinion 2003-13 — Mark F. Beneventi v. Commissioner
    IRCCourt RulingsFeb 20, 2003related by meaning
    …ion references are to the Internal Revenue Code in effect for 1999, the taxable year in issue. T.C. Summary Opinion 2003-13 UNITED STATES TAX COURT MARK F. BENEVENTI, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1558-02S. Filed February 20,2003. Mark F. Beneventi, pro se. Michael K. Park , for…
52. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM Third Party Communication: None Date of Communication: Not Applicable Number: 200648028 Release Date: 12/1/2006 Index (UIL) No.: 6166.00-00, 6403.00-00, 2055.00-00, 2511.02-00, 414 .00-00, 2053.09-00, 2032.00-00 CASE - MIS No.: TAM - 142156-05 AUGUST …
53. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
54. Rev. Rul. 2014-18 — This ruling provides that a nonstatutory stock option or a stock appreciation right (each, a stock right) granted by a nonqualified entity for purposes of sect…
    IRCRevenue RulingsJun 23, 2014related by meaning
    d restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations. Rev. Proc. 2014–35 Rev. Proc. 2014–35 This revenue procedure provides safe harbors for applying the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members. Not…
55. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …19 plan) in 2001 and 2002 and to the Millennium Multiple Welfare Benefit Trust (Millennium plan) in 2003, and respondent's 1Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Proc…
56. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    d to an SEP plan on the basis of these earnings.6 In 2003 he contributed $12,242 to his SEP plan. In the notice of deficiency respondent determined in pertinent part that petitioner was:; (1)- A common law employee of the BCG and consequently was not entitled to report gross receipts and expenses associated with his wo…
57. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    oss-motion for - 3 - summary judgment spursuant to Rule 121. Respondent determined a deficiency of $33,057 in petitioner's Federal rincome tax for tax year 2004 and a penalty pursuant to section -6662(a) of $6,611 On August 31, 2009, petitioner filed a motion-for summary judgment. On October 5,- 2009, respondent filed …
58. T.C. Summary Opinion 2008-1 — Shawn Timothy Hynes v. Commissioner
    IRCCourt RulingsJan 2, 2008
    ork City to Palo Alto . Petitioner timely filed his 2003 Federal income tax return . Petitioner reported wages, salaries, and tips on his return . His wages of $51,304 were earned from his employment at STB from September through December of 2003 . Respondent received the following third party information for petitione…
59. T.C. Memo. 2009-100 — Peter I. & Daria A. Basalyk v. Commissioner
    IRCCourt RulingsMay 14, 2009
    …of the Memphis and Forest Lakes properties were $92,480 and $53,880, respectively . Tax Years 2002, 2003, and 200 4 During 2002, 2003, and 2004 petitioner Daria A . Basalyk (Mrs . Basalyk) was an employee of the Brecksville-Broadview Heights Board of Education . Petitioner Peter I . Basalyk (Mr . Basalyk) was an employ…
60. U.S. Tax Court — Stacey Lynn Reese v. Commissioner
    IRCCourt RulingsFeb 13, 2006
    and was involved in a diving accident and became a quadriplegic . From August 2001 to September 2003, petitioner was employed, but she resigned at the end of 2003 to care for her two young children . During 2003 , because of financial hardship, petitioner took a lump-sum distribution of $32,917 from her 401(k) account …