IRCCourt RulingsDec 19, 1989related by meaning
ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner.
Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
IRCCourt RulingsOct 6, 1988related by meaning
n of the transitional rule and denial of the unlimited marital deduction is, therefore, consistent with, and does not frustrate, congressional intent. Because we have concluded that the marital deduction provision in decedent’s will is a marital deduction formula to which section 403(e)(3) of ERTA applies, the marital …
IRCCourt RulingsNov 21, 2023
…new areas of technology. During the years in issue Mobile paid him a
yearly salary ranging between $154,000 and $159,000.
In addition to working for Mobile, petitioner husband owned and
operated a sole proprietorship from 2006 to 2014. Doing business as
“ K J Marketing ,” petitioner husband identified new markets for
c…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1996-450
UNITED STATES TAX COURT
THEODORE SOURIS, P.C., A DISSOLVED CORPORATION,
AND THEODORE SOURIS, AS SUCCESSOR IN INTEREST
OF THEODORE SOURIS, P.C., Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 639-95. F…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…
1993
1994
A. Investment 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 30,17…
IRCCourt RulingsJul 31, 2000
…reon
equaled the interest rate earned on the policy). The Southland
policy’s accumulated value was $154,483 on December 28, 1994, its
surrender charge for that year was $68,800, and the interest
credited to the policy during that year approximated $5,046.96.
For 1994, a $3.2 million term insurance policy on the life of…
IRCCourt RulingsNov 14, 1996
… States
, 97 F.3d 1435 (Fed. Cir. 1996); Truck & Equipment
Corp. v. Commissioner
, 98 T.C. 141, 145-154 (1992). Second, we
recognize that it does not necessarily follow that funds have
been paid because they have been constructively received for
income tax purposes. See Gillis v. Commissioner
, 63 T.C. 11, 17
(1974). T…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
IRCCourt RulingsFeb 25, 2016
…ed. See Cabirac v.
Commissioner, 120 T.C. 163, 170 (2003); Gleason v. Commissioner, T.C. Memo.
2011-154. A return for section 6020(b) purposes must contain sufficient
information from which to compute the taxpayer's tax liability. Spurlock v.
Commissioner, T.C. Memo. 2003-124. Respondent has produced such
information f…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
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…
IRCCourt RulingsJul 30, 1985related by meaning
the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
IRCCourt RulingsDec 18, 2012
…agrees
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 $815,963, resp…
IRCCourt RulingsMay 28, 1996related by meaning
106 T.C. No. 20
UNITED STATES TAX COURT
ALFRED E. GALLADE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 791-94, 792-94. Filed May 28, 1996.
C, P’s wholly owned corporation, operated a
pension plan in which P participated. Because of C’s
poor financial disposition, P executed a “waiver”, to
as…
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 …
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…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
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…
IRCCourt RulingsOct 3, 1995related by meaning
rovide the written
explanation required by section 402(f) is somehow attributable to
respondent and requires respondent to assume the burden of proof. The short answer to this contention is that we have decided the
issue in dispute without regard to the burden of proof. In any
event, section 402(f) imposes a duty on pl…
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 …