120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
… return 6.6% 6.0% 5.7% 4.9%
B. Present value accrued benefits
a. Active $11,154,103 $30,515,975 $38,396,684 $61,044,923
b. Retired 23,798,600
33,006,450
38,374,995
42,599,819
c. Total 34,952,703 63,522,425 76,771,679 103,644,742
C. Value of assets (beginning of year)
a. VEBA --- 30,736,554 30,176,217 39,940,676
b. 401(…
IRCCourt RulingsOct 2, 1974
…s made a journal entry on B-G’s books, debiting the “Retirement Income Plan” expense account by $27,396.55 and crediting the “Accrual” expense account by the same amount. Earlier in the year B-G had purchased in the name of the plan securities with a value of $7,101.83. On or about May 17,1967, B-G purchased for the pl…
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961related by meaning
e distribution.
Although section 816 of the 1954 Code rather than section 115 of the 1939 Code is applicable here, the relevant language is identical. The dividend issue was raised expressly by respondent for the first time at the trial by the statement that “the amounts involved in this case are * * * a preferential o…
IRCCourt RulingsMay 23, 2011
…xpayer's reliance must be in good faith and demonstrably
reasonable. Ewing v. Commissioner, 91 T.C. 396, 423 (1988),
affd. without published opinion 940 F.2d 1534 (9th Cir. 1991);
Freytag v. Commissioner, supra at 888-889. In such a case, a
taxpayer will be entitled to rely upon an expert's advice, even
if the expert's…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
IRCCourt RulingsDec 29, 2005
…, for 2001, reported that she was married filing
¹ Petitioner concedes that she failed to report $3,396 of
income from Evergreen State College on her Form 1040 for 2001 as
determined by respondent.
- 3 -
separately, and deducted $1,916 for a payment to an individual
retirement account (IRA).
OPINION
A. Whether Petition…
IRCCourt RulingsFeb 28, 2024related by meaning
” —not ours. See United
44
States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
IRCCourt RulingsMar 3, 2016
…iency in Federal income tax
of $36,979 and an accuracy-related penalty under section 6662(a)¹ of $7,396 for
petitioner's 2010 taxable year.
¹Unless otherwise indicated, all section references are to the Internal
Revenue Code, as amended and in effect for the year in issue, and all Rule
references are to the Tax Court R…
IRCCourt RulingsJan 28, 2014related by meaning
vant facts." Lawinger v. Commissioner, 103 T.C. 428, 440 n.8 (1994).
- 24 -
[*24] Substantial authority exists only when the weight of the authorities supporting the treatment of the tax item is substantial in relation to the weight of
the authorities supporting contrary treatment. Sec. 1.6662-4(d)(3)(i), Income Tax
Re…
IRCCourt RulingsNov 21, 2007
… 1998 23 32 .750 750 .6 2
Nov . 19, 1998 8,000 32 .625 260,087 .7 5
Nov . 19, 1998 2,000 32 .812 65,396 .9 2
10,323 32 .737 336,022 .0 8
The above proceeds were invested in a money-market mutua l
fund and earned dividend income in the amount $509 .90 for the
IRCCourt RulingsMar 6, 2001
… years antedating the Supreme Court’s
opinion therein. See, e.g., Bagley v. Commissioner
, 105 T.C. 396
(1995), affd. 121 F.3d 393 (8th Cir. 1997); Green v.
Commissioner
, T.C. Memo. 1998-274; Goeden v. Commissioner
, T.C.
Memo. 1998-18; Wise v. Commissioner
, T.C. Memo. 1998-4; Kroposki
- 13 -
v. Commissioner
, T.C. M…
IRCCourt RulingsMay 21, 1999
…97
Other expenses:
Transportation $967
Telephone 825
Freight charges & postage 483
Location rentals 396
2,671
Total 9,012
Petitioner filed his 1994 return on May 3, 1996. Petitioner
timely filed his 1995 return. Upon examination of the returns,
respondent disallowed all of petitioner's claimed expenses
2
and
cost of go…
IRCCourt RulingsJan 16, 2020
…, 2018, respondent determined that
petitioners are liable for a Federal income tax deficiency of $7,396 and an
accuracy-related penalty of $1,479 for the taxable year 2015 (year in issue).
Petitioners, husband and wife, filed a timely petition for redetermination with the
Court pursuant to section 6213(a). When the pet…
IRCCourt RulingsJul 24, 1984related by meaning
rectly involved in such ruling. * * *”
See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …
IRCCourt RulingsOct 21, 2004
… and this opinion
should not be cited as authority.
- 2 -
Respondent determined deficiencies of $10,396 and $1,056 in
petitioners’ 1998 and 1999 Federal income taxes, respectively.
After concessions by the parties, the sole issue for decision is
whether petitioners are liable for the 10-percent additional tax
under sec…
IRCCourt RulingsMay 20, 1976related by meaning
nd nondeferred compensation must be subject to the reasonable allowance standards set forth in section 162(a)(1). Sec. 1.404(a)-1(b), Income Tax Regs. Petitioners contend that if Congress intended section 404(a) to be subject to reasonable compensation standards, it would have specifically mentioned section 162(a)(1). …
IRCCourt RulingsJul 27, 2004
…itative sources of law in the tax
field. Casa De La Jolla Park, Inc. v. Commissioner
, 94 T.C. 384,
396 (1990). Taxpayers must look to authoritative sources of
Federal tax law such as the statutes, regulations, or judicial
decisions. Green v. Commissioner
, 59 T.C. 456, 458 (1972).
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…48 962,317 95,267,865 4,098,466
6/30/88 112,993,217 1,725,585 114,718,802 6,871,287
6/30/89 143,612,396 4,476,187 147,088,583 9,650,154
6/30/90 159,302,147 2,822,959 162,125,106 11,430,723
6/30/91 149,671,091 2,045,944 151,717,035 2,805,387
On April 1, 1974, BI and Mr. Schoenecker entered into a
written employment agre…
IRCPrivate Letter RulingsMar 10, 2006related by meaning
ration of the taxing statutes. If a ruling is
revoked or modified, the revocation or modification applies to all open years under the
TAM-134113-05
15 statutes, unless the Commissioner or his delegate exercises the discretionary authority
under § 7805(b) to limit the retroactive effect of the revocation or modification…
IRCCourt RulingsFeb 22, 2010related by meaning
ition by stating that the
amended regulations apply in this case to the extent that they
"clarify" the law as it applied during taxable year 2000 with respect to transfers of property occurring before August 29,
2005
.
'on
supplemental brief respondent states that the amended
sec . 402 ( a) regulations are inapplicable…