IRCCourt RulingsMay 28, 1962related by meaning
ion of the period allowed by the statute for such payment), by cash, check, note, property, or otherwise. Cf. Campbell Chain Co., 16 T.C. 1402 (1951). In the instant case it is clear that petitioner had no motive of tax avoidance in not making the payment within the prescribed time. Likewise no motive of tax avoidance …
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
IRCCourt RulingsMar 6, 2001
…314; see also Frick v. Commissioner
,
T.C. Memo. 1985-542, affd. without published opinion 808 F.2d 837
(7th Cir. 1986); Frick v. Commissioner
, T.C. Memo. 1989-86, affd.
without published opinion 916 F.2d 715 (7th Cir. 1990).
In the case at hand, petitioner applied to become a State
Farm trainee agent in fall 1976 or …
IRCCourt RulingsOct 17, 1995
…9 6,503.89 6,503.89 -0Repairs 4,112.10 5,487.10 5,487.10 -0Taxes 220.00 435.43 435.43 -0Utilities 3,837.35 5,503.09 5,503.09 -0Telephone 587.75 -0- 1,342.33 (1,342.33)
Miscellaneous -0- 8,331.42 -0- 8,331.42
Meals -0- -0- 662.73 (662.73)
Depreciation 2,248.00
2,889.00
2,889.00
-0-
Total 20,603.76
37,494.61
28,331.15
9,…
IRCCourt RulingsApr 12, 1976related by meaning
ishable, we need not invoke our holding in Jack E. Golsen, 54 T.C. 742 (1970), affd. 445 F. 2d 985 (10th Cir. 1971), cert. denied 404 U.S. 940 (1971). Petitioner has cited Rev. Rul. 72-440, 1972-2 C.B. 225, wherein the Internal Revenue Service revoked a series of earlier rulings and took the position that an employee w…
IRCCourt RulingsAug 6, 1996
…they must give way to the statute. See also
Chevron, U.S.A. v. Natural Res. Def. Council
, 467 U.S. 837, 842843 (1984).
We have considered petitioner's remaining arguments, which
are basically variations on a theme, and find them equally
unpersuasive.
We hold that petitioner's grace period contributions, except
those t…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006related by meaning
nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A).
(48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
IRCCourt RulingsApr 11, 2012related by meaning
nt and
other official explanations of such treaties; court cases; congressional
intent as reflected in committee reports, joint explanatory statements of managers included in conference committee reports, and floor
statements made prior to enactment by one of a lhill's managers;
General Explanations of tax legislation …
IRCCourt RulingsMay 20, 1976related by meaning
es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
IRCCourt RulingsJun 6, 2005
… early
distributions unless otherwise specifically exempted. Roundy v.
Commissioner
, 122 F.3d 835, 837 (9th Cir. 1997), affg. T.C. Memo.
1995-298.
Accordingly, respondent’s determination that petitioners are
liable for the 10-percent additional tax is sustained.
Reviewed and adopted as the report of the Small Tax Case…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
IRCCourt RulingsJun 14, 2012related by meaning
ess doctrine, courts may invalidate laws if "'men of common
intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor
- - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945
F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra
addresses tran…
IRCCourt RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
IRCCourt RulingsSep 28, 2022related by meaning
es applicable t o annuity distributions from CRATs. Thus, to
the extent sections 72 and 664 called for different treatment, section 664
would control. Second, section 7 2 do es not call for different treatment. Section
72(b)(1) allows an exclusion from income only to the extent the taxpayer
has an “investment in the co…
IRCCourt RulingsNov 4, 1976related by meaning
loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
IRCCourt RulingsNov 25, 2002related by meaning
(c)(2).
Thus, we sustain respondent’s determination on this issue.
C. Petitioner’s IRA Deductions
As a preliminary matter, we note that deductions are strictly a matter of legislative grace, and a taxpayer bears the
burden of proving his or her entitlement to the claimed
deductions.
18
Rule 142(a)(1); see New Colonial …
IRCCourt RulingsDec 2, 2010
… books or records to substantiate all claimed deductions.
Roberts v. Commissioner, 62 T.C. 834, 836-837 (1974) .
"Sec. 1401 imposes, in addition to other taxes, a- tax of
12.40 percent on the self-employment income of every individual.
One -half-of this tax-is then deductible f rom adjusted gross
income (AGI) under sec…