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83 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    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…
  2. 91 T.C. 769; 91 T.C. No. 49 — Estate of Christmas v. Commissioner
    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 …
  3. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    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…
  4. 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…
  5. 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…
  6. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    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…
  7. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    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…
  8. 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…
  9. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    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…
  10. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    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…
  11. 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…
  12. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    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 …
  13. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    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…
  14. 106 T.C. No. 20 — Alfred E. Gallade v. Commissioner
    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…
  15. 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 …
  16. 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…
  17. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    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…
  18. 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…
  19. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    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…
  20. 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 …