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61. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    …7; for a 92 day period (October 19, 1987 to January 1, 1988) at 7% interest yields $3,016.44; for a 121 day period (January 18, 1988 to May 17, 1988) at 6.65% interest yields $3,763.97; for a 121 day period (May 17, 1988 to September 14, 1988) at 6.75% interest yields $3,820.57; and for a 365 day period (September 14, …
62. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
63. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    … Court disagrees with this treatment, the respective deficiencies are $108,656, $67,059, $126,860, $121,404, $154,258, and $117,884. We decide the following issues:4 1. whether petitioners' gross income for the subject years includes nonemployee compensation of $483,591, $487,873, $536,145, $628,500, $694,986, and $815…
64. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    or the respondent. All section references are to the Internal Revenue Code of 1954, as in effect during the tax year in issue, unless otherwise noted. In a letter dated Dee. 7,1978, an appeals officer objected to the plan in its original form because, in part, the plan contained no provision requiring full vesting upon…
65. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
66. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
67. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011
    … there is no genuine issue of materïal fact and a decision may be rendered as a matter of law. Rule 121(a) and (b); Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). The moving party bears the burden of proving that there is.no genuine issue of material fact, and factual inferences are.viewed in a light most f…
68. T.C. Summary Opinion 2007-187 — Wayne Smith v. Commissioner
    IRCCourt RulingsNov 1, 2007
    …e is no genuine issue of any material fact and a decision may be rendered as a matter of law . Rule 121(a) and (b) ; see Sundstrand Corp . v . Commissioner , 98 T .C . 518, 520 (1992), affd . 17 F .3d 965 (7th Cir . 1994) . The moving party bears the burden of proving that there is no genuine issue of material fact, an…
69. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    Eanes as petitioner. In his answer, filed May 2,1985, respondent claimed an increased deficiency of $90 in excise tax pursuant to secs. 4973 and 6214. Sec. 219 has been amended to allow persons covered by qualified plans to take deductions for contributions to IRA’s in taxable years beginning after Dec. 31, 1981. See s…
70. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003
    121 T.C. No. 14 UNITED STATES TAX COURT JIMMY D. WEAVER AND MARLENE M. MORLOC WEAVER, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8262-01. Filed October 8, 2003. P owned 80-percent interests in an S corporation (CL) and a C corporation (J). CL is an accrual method, calendar year taxpayer. J …
71. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …ming, and unnecessary trials. Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Under Rule 121( a ), we may grant summary judgment when there is no genuine dispute as to any material facts and a decision may be rendered as a matter of law. Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (19 92 ) , aff’d , 1…
72. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    been finalized. Moreover, even if the proposed regulation were final, it would not, by its terms, apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2, 1998) (regulation applies to "loans made on or after the date that is three months after the date of publication o…
73. 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…
74. T.C. Memo. 2002-30 — Drew Allen Rayner v. Commissioner
    IRCCourt RulingsJan 28, 2002
    …randum. Discussion A. Respondent’s Motion for Summary Judgment Respondent filed a motion under Rule 121(b) seeking summary judgment upholding the determination in the notice of deficiency. We may grant summary judgment if there is no genuine issue of material fact and a decision may be rendered as a matter of law. Rule…
75. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…
76. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    …ss From Law Firm Partnership The first issue for d ecision is whether petitioner was entitled to a $121,500 loss deduction due to his withdrawal from the Heidelberg & Woodliff law firm partnership. Petitioner asserts that the $121,500 loss represents the value of accounts receivable and work in progress, along with oth…
77. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
78. T.C. Memo. 2016-28 — Raymond S. McGaugh v. Commissioner
    IRCCourt RulingsFeb 24, 2016
    … matter is currently before the Court on Mr. McGaugh's motion for summary judgment pursuant to Rule 121, which the Commissioner has opposed. The issue for decision is whether a transaction involving the removal of $50,000 from Mr. McGaugh's IRA to purchase stock for his IRA constituted a distribution that was not rolle…
79. T.C. Memo. 2015-47 — Balvin Anthony McKnight v. Commissioner
    IRCCourt RulingsMar 16, 2015
    …ming, and unnecessary trials. Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Under Rule 121(b) the Court may grant summary judgment when there is no genuine dispute as to any material fact and a decision may be rendered as a matter of law. Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff'd, 17…
80. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …rty 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 decision may be rendered as a matter of law. Rule 121(b); Craiq v. Commissi…