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75 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    …mber 21, 1988. Petitioners bear the burden of proof on this issue. Abramo v. Commissioner , 78 T.C. 154, 163 (1982). Petitioners did not address this issue on brief, nor is there any evidence in the record that would lead us to conclude that they had a reasonable excuse for not filing their 1987 return until November 2…
  2. T.C. Memo. 2025-23 — Charlie Campana v. Commissioner
    IRCCourt RulingsMar 19, 2025related by meaning
    United States Tax Court T.C. Memo. 2025-23 CHARLIE CAMPANA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent __________ Docket No. 15766-23. Filed March 19, 2025. __________ Charlie Campana , pro se. Bianca L. Thomas and Daniel C. Munce, for respondent. MEMORANDUM FINDINGS OF FACT A ND OPINION PUGH , Judge : …
  3. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024
    …statute of limitations does not affect a party’s underlying liability. Cf. Wilson v. Pena , 79 F.3d 154, 162 (D.C. Cir. 1996) (explaining that extending a limitations period “d[id] not alter the legal effect of any pre-amendment event, nor d[id] it change the remedies available for pre-amendment violations”) ; Forest v…
  4. 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…
  5. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996
    … On their income tax return for 1990, petitioners reported taxable interest in the total amount of $154,613. Of this amount, $150,000 represented a distribution from petitioner's IRA with First National, which petitioners characterized as an early withdrawal. The balance represented interest income from unrelated bank …
  6. T.C. Summary Opinion 2015-48 — Joshua W. Pingel v. Commissioner
    IRCCourt RulingsAug 10, 2015related by meaning
    mmissioner, 131 T.C. 185 (2008), supplementing T.C. Memo. 2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144. - 12 - II. Section 1839 A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and necessary expenses incurred in conducting a trade or business or for the production of income. Se…
  7. 114 T.C. No. 17 — Michael G. Bunney v. Commissioner
    IRCCourt RulingsApr 10, 2000
    …. Commissioner , 97 T.C. 51, 58 (1991); see also Estate of Machat v. Commissioner , T.C. Memo. 1998-154. Under this definition, petitioner would be the distributee and the payee because he was the IRA participant and received the distributions according to the terms of his IRA’s. Similarly, petitioner’s former spouse w…
  8. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  9. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  10. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ons of the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. - 3 - After concessions, the following 2 issues remain for us to resolve in the present proceeding: (1) Whether petitioner, in its taxable year ending January 30, 1988 (TYE 88…
  11. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    IRCCourt RulingsJan 20, 1983related by meaning
    on 412 and contravene statutory flexibility with respect to actuarial assumptions to be used, citing H. Rept. 93-779 (1974), 1974-3 C.B. 244, 269-270. After careful consideration, we do not regard the language of the reports accompanying TEFRA, i.e., the statements that the addition to section 404 (with cross-reference…
  12. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008
    …Finally, using traditional methods of financial calculation, we believe that annual payments of $26,154 .16 would have to be made to amortize $286,000 over 27 years at 8 percent interest . According to our calculation, we also believe that annual payments of $24,408 .58 would be necessary in order to amortize $286,000 …
  13. T.C. Summary Opinion 2003-103 — Santos M. & Ingrid I. Castillo v. Commissioner
    IRCCourt RulingsJul 24, 2003related by meaning
    1 Unless otherwise indicated, section references hereafter are to the Internal Revenue Code in effect for the year at issue. T.C. Summary Opinion 2003-103 UNITED STATES TAX COURT SANTOS M. AND INGRID I. CASTILLO, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4698-02S. Filed July 24, 2003. Sant…
  14. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
    IRCCourt RulingsAug 13, 1999
    …,614 in its account with Prudential, and Sklar, Greenstein, and Scheer invested collectively $1,323,154. 2 By 1991, Sklar, Greenstein, Sheer, their respective spouses, and the plan (collectively referred to as the claimants) were dissatisfied with Zahn's account management and filed a complaint with the American Arbitr…
  15. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related 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. 2 All dollar amounts are rounded to the nearest dollar. 3 Petitioner concedes that he is not entitled to the $24,248 alimony deduction that he claimed on his 2007 Federa…