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61. 143 T.C. No. 11 — Dennis E. Bohner v. Commissioner
    IRCCourt RulingsSep 23, 2014related by meaning
    pretation of the statute was "unduly narrow" and ran counter to the plain meaning of the statute), rev'g 102 T.C. 61 (1994); Matthews v. Commissioner, 907 F.2d 1173, 1179 (D.C. Cir. 1990) (holding that the language of the statute is "too plain to be mistaken"), aff'g 92 T.C. 351 (1989). And the Supreme Court has remind…
62. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …mendment to of deficiency answer 2003 Deficiency $1,252,944 $1,862,245 Sec. 6662(a) penalty 250,589 372,449 2004 Deficiency 471,615 1,932,273 Sec. 6662(a) penalty 94,323-386,455 For both years the increased deficiencies result from respondent's determination to totally disallow the management fee deductions claimed on …
63. T.C. Memo. 1997-348 — Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, C.T.A. v. Commissioner
    IRCCourt RulingsJul 29, 1997
    …ondent, after making numerous adjustments that increased decedent's gross estate, disallowed $1,701,372 of the claimed marital deduction. -7- OPINION In general, a marital deduction is available in computing the taxable estate of a decedent for the value of all property interests passing from the decedent to the surviv…
64. 75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac…
    IRCFinal Rules (FR)Jul 6, 2010related by meaning
    ) under section 408(q)); and (D) Roth IRAs under section 408A. (ii) Arrangements described in section 220(d) (Archer Medical Savings Accounts (MSAs)); (iii) Arrangements described in section 403(b)(7) (custodial accounts treated as annuity contracts); (iv) Arrangements described in section 530 (Coverdell education savi…
65. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012
    …uded in its gross income the. payments from SGR and WFR and reported gross income of $163,596, $122,372,.and $75,792 for 2004, 2005, and 2006, respectively. Yolo paid Federal income taxes of $34,395, $15,484, and $5,911 for its tax years ending October 31, 2004, 2005, and·2006, respectively. Respondent did not adjust f…
66. 58 T.C. 241 — Estate of Kleemeier v. Commissioner
    IRCCourt RulingsMay 8, 1972related by meaning
    computed. The repetitious reference to “the decedent” indicates that the statute is addressing itself to the particular decedent who was the employee. The statute does not refer to “a decedent” which might connote its applicability to any decedent whether or not that decedent was the employee for whom the annuity was p…
67. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    … Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) 2002 $4,889 $1,100 $1,222 2003 6,148 1,383 1,537 2004 6,372 1,433 (¹) 2005 6,817 1,533 (¹) 2006 7,850 1,766 (¹) 2007 8,616 1,938 (¹) ¹Amounts to be determined. While residing in California, petitioners timely petitioned this Court with respect to both notices of deficiency. T…
68. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …ment entered into on January 24, 1994. The parties agreed at that time to a total deficiency of $11,372.40, which reflected an amount conceded by petitioners in their petition as capital gain inadvertently omitted from their 1988 Federal income tax. A stipulated decision (hereinafter the decision) was submitted by the …
69. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
70. T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred…
    IRCTreasury DecisionsFeb 6, 2006related by meaning
    idance concerning the requirements for designated Roth contributions under qualified cash or deferred arrangements. EMPLOYMENT TAX T.D. 9239 T.D. 9239 Final, temporary, and proposed regulations under section 6011 of the Code relate to the time for employers to file returns and make deposits under the Federal Insurance …
71. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
    IRCCourt RulingsMay 29, 1968
    …C. 133, 135 (1965). See also H. Rept. No. 2333, 77th Cong., 2d Sess., pp. 50-51 (1942), 1942-2 C.B. 372. For a contrary Indication, see the definition of “profit-sharing plan” in Income Tax Regs., see. 1.401-1 (b) (1) (ii). Sec. 404(b). Method of Contributions, Etc., Haying the Effect of a Plan. — If there Is no plan b…
72. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
73. 68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner
    IRCCourt RulingsSep 12, 1977
    …holders, officials, or highly paid employees.” H. Rept. No. 2333, 77th Cong., 2d Sess., 1942-2 C.B. 372,450. Respondent then concludes that the benefits and contributions received by the high percentage of highly compensated employees were discriminatory under section 401(a)(4). We agree that petitioner’s plan was oper…
74. 70 T.C. 139 — Ziegler v. Commissioner
    IRCCourt RulingsMay 2, 1978
    …d adjudicate what interpretation carries out the legislative purpose. See United States v. Gilmore, 372 U.S. 39, 44-45 (1963); Doing v. Commissioner, 58 T.C. 115, 129 (1972); Southern California Loan Association v. Commissioner, 4 B.T.A. 228,233-234 (1926).
75. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000
    …)(C); Hemmings v. Commissioner , 104 T.C. 221, 226 n.6 (1995); Boyd v. Commissioner , 101 T.C. 365, 372-73 (1993). Petitioners rely incorrectly on Roberts v. Commissioner , 94 T.C. 853 (1990), for a contrary result. There, the Commissioner issued notices of deficiency disallowing the taxpayers' claimed losses from TEFR…
76. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    , 1st Sess. (1962), 1962-3 C.B. 268-269; S. Rept. 992, 87th Cong., 1st Sess. (1962), 1962-3 C.B. 303, 328. See Rev. Rui. 61-157,1961-2 C.B. 67, 87-88. We note that prior to amendment by ERISA, the antidiscrimination provisions of secs. 401(a)(3)(B) and 401(a)(4) provided a facts and circumstances test to determine whet…
77. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    …66) Investments 420,000 -0--0-923,755 1,626,112 Receivables due from employer 1,725,684 2,388,824 2,372,554 516,399 -0- Total assets 2,145,784 2,408,732 2,391,486 1,491,446 1,599,746 Liabilities: Unpaid claims 379,002 377,225 327,989 857,071 853,771 Net Assets 1.766,782 2.031.507 2.063.497 634,375 745,975 The financial…
78. T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.…
    IRCTreasury DecisionsApr 30, 2007related by meaning
    ing Families Tax Relief Act of 2004, Public Law 108-311 (118 Stat. 1166) (WFTRA), the Gulf Opportunity Zone Act of 2005, Public Law 109-135 (119 Stat. 2577) (GOZA), and the Pension Protection Act of 2006, Public Law 109-280 (120 Stat. 780) (PPA ’06). Although some limited changes to the regulations were made after 1981…