IRCCourt RulingsJul 15, 1997related by meaning
3,200.
5,000 furniture and The corporation conceded
fixtures entire amount to be not
deductible; respondent allowed
- 21 -
additional ACRS deductions pursuant to section 168.
Taxable Year Ending December 31, 1987
Amount of Purpose of
deduction claimed deduction claimed
by the corporation
by the corporation
Concessions…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
IRCCourt RulingsMar 9, 2011related by meaning
4 (1984); see United
States v. Mead Corp., 533 U.S. 218 (2001). Although they may be
entitled to deference under Skidmore v. Swift & Co., 323 U.S. 134 (1944), see United States v. Mead Corp., supra, we need not
decide whether Notice 2004-8, supra, should be given Skidmore
deference because the Transaction does not féll…
IRCCourt RulingsNov 14, 1996related by meaning
rst articulated.
3
As a
consequence, we set forth that analysis in order to bring into
focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid"
when the letter of credit was purchased on March 13, 1992.
Statutory Framework
The parties have stipula…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsSep 30, 2003related by meaning
ance with its substance.”
Neonatology Associates, P.A. v. Commissioner
, 299 F.3d 221, 230
n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is
free to organize his affairs as he chooses, nevertheless, once
having done so, he must accept the tax co…
IRCCourt RulingsJan 27, 1998related by meaning
ven or the amount of
money and the fair market value of the property received. Sec.
-134975(f)(4). Since the prohibited transaction was the assignment of the accounts receivable by the Corporation to the Plan, the
amount involved is the fair market value of the accounts
receivable on May 31, 1988. In the notice of defi…
IRCCourt RulingsApr 18, 1984related by meaning
.e., the amount received under the Act in excess of the amount contributed to the retirement program by taxpayer is taxable income. [326 F.2d at 968.] We note that the Commissioner has acknowledged that a Civil Service employee who resigns and later reenters Civil Service employment and who elects to repay to the U.S. …
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
IRCCourt RulingsMar 27, 1989related by meaning
ended returns, The conditions were not met, and it was not an abuse of discretion to disqualify the plan.
Revocation of Favorable Determination Letter The Supreme Court has held that the Commissioner has broad discretion under section 7805(b) in deciding whether to revoke a ruling retroactively, and that his determinat…
IRCCourt RulingsAug 6, 1997related by meaning
Motion for a Section 6673 Penalty
Respondent submitted a motion for the imposition of a
penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an
amount not to exceed $25,000 whenever it appears that the
taxpayer's position in a proceeding is frivolous,…
IRCCourt RulingsMay 11, 2009related by meaning
ubstantially equal
periodic payments . In Arnold , we stated : "In order to avoid the
section 72(t) tax, petitioners must show .that the November 1993 distribution falls within one of the exceptions provided under
section 72(t)(2)(A) . They have not done so ." Id . at 255 . Today
we also recognize .that distributions u…
IRCCourt RulingsDec 11, 1997related by meaning
o be
treated as an amount received as a loan on the date of such
renegotiation, extension, renewal, or revision. TEFRA, sec.
236(c), 96 Stat. 510-511. In general, a loan fits within the exception in section 72(p)(2)
if it (1) is in an amount not exceeding a prescribed ceiling that
in no event may be more than $50,000, …
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
IRCCourt RulingsOct 2, 1974related by meaning
may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…