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61. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    t "on account of" the earlier tax year in that the taxpayer had not proven that the "same treatment requirement" of Rev. Rul. 76-28 was satisfied. Id. (The only grace period contributions that we find to be "on account of" TYE 8801 and which, consequently, must be deducted in that year, are any delinquent payments and …
62. T.C. Memo. 2007-360 — Rodolfo & Bernadette Domingo v. Commissioner
    IRCCourt RulingsDec 5, 2007
    …ecember 28, 1995, was paid timely with a dividend withdrawal of $10,358 .01 and a withdrawal of $42,735 .12 from the PUAR . In 1997, the premium due on December 28, 1996, was paid timely with a dividend withdrawal of $10,416 .38 and a withdrawal of $42,676 .75 from the PUAR . The premium due on December 28, 1997, was n…
63. 85 T.C. 1031; 85 T.C. No. 60 — Anesthesia Service Medical Group, Inc. v. Commissioner
    IRCCourt RulingsDec 24, 1985
    … benefits nevertheless was not unreasonable. Cf. Bricklayers Benefit Plans v. Commissioner, 81 T.C. 735 (1983); Water Quality Association Employees’ Benefit Corp. v. United States, 609 F. Supp. 91 (N.D. Ill. 1985).
64. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
65. 90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements
    PBGCFinal Rules (FR)Aug 15, 2025
    …ore, PBGC estimated that the annual burden for complying with this collection of information was 41,735 hours and $8,509,740.
66. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025related by meaning
    ayer raised that issue at the CDP hearing. See Hoyle v. Commissioner, 131 T.C. 197, 202 – 03 (2008), supplemented by 136 T.C. 463 (2011). MDIA did not allege in the Petition that AO Alves failed to satisfy this requirement and has set forth no specific facts as to this matter. See Rules 121(d), 9 The Court notes that d…
67. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
68. 137 T.C. No. 2 — Robert K. & Joan L. Paschall v. Commissioner
    IRCCourt RulingsJul 5, 2011
    …s Haywood Lumber & Mining Co. v. Co missioner, 178 F.2d 769, 771 (2d Cirs 1950) , modifying 12 T.C. 735 (1949), orient Inv.- & Fin. Co. v. Commiasioner, 166 F.2d 601 (D.C. Cir. 1948) , and Hatfried, Inc. v. Commissioner, 162 F.2d 628 (3d Cir. 1947) . Unlike the case
69. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023related by meaning
    n its trade or business, including “ rentals or other payments required to be made as a condition to the continued use or possession ” of property. 19 Respondent also contends that petitioners failed to substantiate some of the reported rent payments. Because we sustain respondent’s determination on other grounds, we n…
70. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …n the N otice) to Facebook US’s deductions for IDCs for 2010, resulting in a reduced deficiency of $735,020 attributable to this item . OPINION Before we tackle the parties’ legal arguments we address threshold evidentiary and procedural matters. We first address petitioner’s contention that respondent raised a “new ma…
71. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ed work in her capacity as Yolo's employee or officer. Consistent with our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties A. s Burden of Proof Respondent bears the burden of production with regard to the section 6651(a)(1) and (2) additions to tax and the …
72. T.D. 9294 — Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recip…
    IRCTreasury DecisionsNov 27, 2006related by meaning
    lans. * * * * * Par. 9. Section 1.7476-2 is amended by revising paragraph (c)(2) to read as follows: §1.7476-2 Notice to interested parties. * * * * * (c) * * * (2) If the notice to interested parties is delivered using an electronic medium under an electronic system that satisfies the applicable notice requirements of…
73. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    stituting a 6-year period in lieu of the 3-year period otherwise referred to in such subsection. (D) Exception for certain acquisitions of property. — In the case of any tax imposed by section 4973 that is attributable to acquiring property for less than fair market value, subparagraph (A) shall not apply. Section 313(…
74. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004
    …c. 4975(a) Sec. 4975(b) Sec. 6651(a)(1) 1996 $1,016 -- $254.00 1997 3,252 -- 813.00 1998 6,941 -- 1,735.25 1999 10,999 -- 2,749.75 2000 15,463 -- 3,865.75 2001 -- $124,079 12,398.00 We decide whether petitioner is liable for these amounts. We hold he is. Unless otherwise stated, section references are to the applicable…
75. 37 T.C. 7 — Barbourville Brick Co. v. Commissioner
    IRCCourt RulingsOct 9, 1961
    …, 23 T.C. 1105, 1112 (1955), remanded on other issues sub nom. Drybrough v. Commissioner, 238 F. 2d 735 (C.A. 6, 1956). See Fifth Avenue Coach Lines, Inc., supra. Whether or not a payment by a corporation to its stockholders is a distribution amounting to a dividend under section 115 (a) is primarily a question of fact…
76. T.C. Memo. 2008-249 — David A. Hughes v. Commissioner
    IRCCourt RulingsNov 3, 2008related by meaning
    rea other compensation for pers o E . Depreciation and Se A,taxpayer may elect to cost, within certain dollar ns t o ons t Pension or Profit-Sharin g > pension or profit-sharin g resection 404 unless they ar e as ordinary and necessary expenses . tates , 501 F .2d 675, 679 (7th Cir . come Tax Regs . Section 162(a)(1) …
77. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
78. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
79. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM January 07, 2004 Number: 200424004 Release Date: 6/11/04 Third Party Contact: Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04 CASE-MIS No.: TAM- 127815-03, CC:ITA:B07 Industry Director ------------------------------------------------ Taxpayer's Name…
80. T.C. Memo. 2020-25 — Alvin E. Keels, Sr. v. Commissioner
    IRCCourt RulingsFeb 19, 2020
    …ns and fees 800 Insurance (other than health) 3,900 Legal and professional services 2,800 Repairs 1,735 Supplies 7,201 Tax and licenses 3,631 Travel 4,804 Meals and entertainment 3,918 Wages 47,468 - 7 - [*7] 2014 Schedule A deductions Mortgage interest 41,000 Donations 489 ii. Disallowed Deductions The notice disallow…