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61. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    C, sec . 408 , SERVED NOV 2 5 2088 I - 2 - 120 Stat . 3061 (TRHCA sec . 408) . TRHCA sec . 408(a) and (c), 120 Stat . 3061, 3062, amended former sec . 6015(e)(1), I .R .C ., to clarify that the Court has jurisdiction to decide a nondeficiency sec . 6015(f) case involving the taxpayer's "liability for taxes arising or r…
62. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995
    … for the same amount was issued in Sept. 1989 after petitioner retired. 6 The sum of the earnings ($183,205.77) and "pick-up contributions" ($1,582.68) equals $184,788.45. In the notice of (continued...) 1989. At the time of his retirement, petitioner was 54 years old. The Retirement System is a qualified defined benef…
63. PLR 200548031 — Additional Tax
    IRCPrivate Letter RulingsDec 2, 2005related by meaning
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64. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
65. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ddress the income tax consequences of the recharacterization of the DISC commissions. However, respondent's position that a transaction may be treated differently under different tax regimes seeds, on the surface, to have some support in 'cases which have held -that the income and gift tax statutes are not read in conj…
66. 98 T.C. 503; 98 T.C. No. 34 — Fowler v. Commissioner
    IRCCourt RulingsApr 22, 1992related by meaning
    Finally, petitioners argue that a literal reading of section 402(e)(4)(B) leads to absurd results. In support of their argument, petitioners provide several examples of the disparate treatment among taxpayers that emanates from a literal application of section 402(e)(4)(B). Granted that a literal reading may, under cer…
67. T.C. Summary Opinion 2013-11 — Steven L. Jarvis, and Estate of Cynthia S. Jarvis, Deceased, Steven L. Jarvis, Special Administrator v. Commissioner
    IRCCourt RulingsFeb 19, 2013
    …ved. See Minnis v. Commissioner, 71 T.C. 1049, 1054 (1979); Ledger v. Commissioner, T.C. Memo. 2011-183; Atwood v. Commissioner, T.C. Memo. 1999-61. When Lincoln National Insurance Co. terminated petitioner husband's policy, the amounts of his policy loans and capitalized interest were charged against the proceeds from…
68. T.C. Memo. 1997-348 — Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, C.T.A. v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    le provides that if: (A) the decedent dies after December 31, 1981, (B) by reason of the death of the decedent property passes from the decedent or is acquired from the decedent under a will executed * * * [before September 12, 1981] or a trust created before such date, which contains a formula expressly providing that…
69. 58 T.C. 241 — Estate of Kleemeier v. Commissioner
    IRCCourt RulingsMay 8, 1972related by meaning
    is exempt from tar under sec. 501(a).” Sec. 170(b) (1) (A) (ii) and (vi) are substantially identical to sec. 503(b) (2) and 503(b) (3), respectively. The final statement In petitioner’s original brief is to the general effect that a payment excludable under subsee. 2039(c)(3) is not includable in decedent’s; gross est…
70. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …a ; Thomas v. Commissioner , 84 T.C. 1244, 1269 (1985), affd. 792 F.2d 1256 (4th Cir. 1986); sec. 1.183-2(a), Income Tax Regs. The promoters and partners knew enough to stress at trial their personal hopes of great profits. Thus, while Fred urged them to "tell the truth", he also reminded the partners that their attorn…
71. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…