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82 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 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(…
  2. 63 T.C. 11 — Gillis v. Commissioner
    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…
  3. 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…
  4. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    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…
  5. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    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…
  6. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    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…
  7. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    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.
  8. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    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…
  9. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    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…
  10. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    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
  11. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    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…
  12. T.C. Memo. 1999-174 — Chrys L. Udoh v. Commissioner
    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…
  13. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    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…
  14. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    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 …
  15. T.C. Summary Opinion 2004-146 — Jack A. & Theresa Y. Smith v. Commissioner
    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…
  16. 66 T.C. 324 — Bianchi v. Commissioner
    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). …
  17. T.C. Summary Opinion 2004-100 — Kurt Steven & Juanita Fay Urban v. Commissioner
    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).
  18. 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…
  19. PLR 200610016 — Year of Deduction
    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…
  20. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    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…