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61. T.C. Summary Opinion 2009-77 — Gary W. & Regina G. Steele v. Commissioner
    IRCCourt RulingsMay 14, 2009
    …,150 payment was attributable to the payment of qualified residence interest . Furthermore, section 461(a) provides that deductions "shall be taken for the taxable year which is .the proper taxable year under the method of accounting used in computing taxable income ." Since petitioners are cash method calendar year ta…
62. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    ust decide (1) whether section 4979A(a) imposes an excise tax on petitioner for its taxable year 2005 and (2) if so, whether the period of limitations under section 4979A(e)(2)(D) has expired for assessing that tax for that year. We turn first to whether section 4979A(a) imposes an excise tax on petitioner for its taxa…
63. T.C. Summary Opinion 2002-108 — Claudia J. Dunn v. Commissioner
    IRCCourt RulingsAug 22, 2002
    …r the taxable year in which actually made”. Sec. 1.446-1(c)(1)(i), Income Tax Regs.; see secs. 446, 461; sec. 1.461-1(a)(1), Income Tax Regs. Petitioner’s higher education expenses for 1998 are limited to the qualified higher education expenses that she actually paid during 1998. Accordingly, only $261.47 of petitioner…
64. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
65. T.C. Memo. 1997-8 — Gary Benton & Karen Ruth Logsdon v. Commissioner
    IRCCourt RulingsJan 6, 1997related by meaning
    etitioners are liable for an accuracy-related penalty of $4,870 pursuant to section 6662(a) for 1991. Section 6662 imposes a 20-percent penalty on any portion of any underpayment that is attributable to any substantial understatement of income tax. Sec. 6662(a)(2), - 14 - (b)(2). Respondent based the determination of t…
66. T.C. Memo. 2010-42 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsMar 4, 2010
    …5 of which was taxable . Petitioner made no Federal income tax payments for 2003 apart from the $10,461 his employer withheld from his wages during the year . On his 2003 Form 1040, U .S . Individual Income Tax Return, petitioner reported zero wages and $2,735 of taxable pension and annuity income ; he claimed the stan…
67. U.S. Tax Court — John C. Armbrust v. Commissioner
    IRCCourt RulingsJan 19, 2010
    … r 72(t)(2) (E) ,and . (F) to include distributions from qualified retirement plans . :See, e .g ., Uscinski v . Commissioner , T .C . Memo . 2 .005-124 (education expenses paid from a section .401(k)_
68. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    foregoing quoted terms are specially defined and used under the "Public Salary Tax Act of 1939" ; 3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor "taxpayer," nor "non-resident alien," nor any other "legal entity" "made liable for" or "subject to" any "internal reve…
69. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973
    … for the periods that such nonbusiness use applied. OPINION 1. Workmen's Compensation Issue Section 461, I.K.C. 1954, provides that a deduction allowed under the Code shall be taken for the taxable year which is the proper taxable year under the method of accounting used in computing taxable income. Under an accrual me…
70. T.C. Memo. 2009-133 — Paul Rudnick v. Commissioner
    IRCCourt RulingsJun 9, 2009related by meaning
    oner is liable for the accuracy-related penalty under section 6662 on the ground tha t 'there was a substantial understatement of income tax in 2004 . Section 6662(a) and (!b)(2) authorizes the Commissioner to impose a 20-percent penalty .if there is a substantial understatement of income tax . A substantial understate…
71. 62 T.C. 166; 14 U.C.C. Rep. Serv. (West) 1165 — Don E. Williams Co. v. Commissioner
    IRCCourt RulingsMay 14, 1974
    …axpayer incurs a liability to make the contribution, the amount of which is aecruable under section 461 for such taxable year. See section 461 and the regulations thereunder. There is another exception in the case of certain taxpayers who are required to make additional contributions as a result of the Act of June 15, …
72. 24 T.C. 460 — Northwest Automatic Products Corp. v. United States
    IRCCourt RulingsJun 23, 1955related by meaning
    a determination of whether we had jurisdiction or not once it should be held that the method prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943…
73. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984
    … attention the opinion of the Court of Appeals for the Seventh Circuit in Gunnison v. Commissioner, 461 F.2d 496 (1972), affg. 54 T.C. 1766 (1970). In Gunnison, it was held that the taxpayer was not entitled to lump-sum distribution treatment for distributions received by him from an exempt trust which was part of a ta…
74. T.C. Summary Opinion 2014-18 — Thomas Wesley Alexander & Sylvia Alexander v. Commissioner
    IRCCourt RulingsFeb 26, 2014related by meaning
    ion 7491(c) imposes on the Commissioner the burden of production in any court proceeding with respect to the liability of any individual for penalties and additions to tax. Higbee v. Commissioner, 116 T.C. 438, 446 (2001); Trowbridge v. Commissioner, T.C. Memo. 2003-164, aff'd, 378 F.3d 432 (5th Cir. 2004). In order to…
75. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …luation Date Boren Steel . 458 Hours of Service Citrus Valley . 460 Old Frontier. 460 Boren Steel . 461 Section 4972 Excise Tax. 461 Section 6651 Failure to File Addition to Tax . 462 Section 6659A Additions to Tax . 463 Conclusions . 465 OPINION Clapp, Judge: Respondent determined the following deficiencies in and add…
76. T.C. Memo. 2000-391 — Robert C. Geib v. Commissioner
    IRCCourt RulingsDec 28, 2000related by meaning
    filed a voluntary petition for reorganization under chapter 11 of the Bankruptcy Code (the bankruptcy case). In the bankruptcy case, the Commissioner asserted a section 4971 deficiency against the company for - 4 - failure to satisfy the minimum funding standard pursuant to section 412. In 1994, petitioner was indicte…
77. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    …pondent points out that this transaction was a part II transaction of the type described in section 461(a) (1) (E), part II, sub-chapter D, and that Kimble Glass became an acquiring corporation, and Owens-Illinois became a component corporation within the definitions contained in section 461 (a) and (b). The petitioner…