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82 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    on. Background The following facts are derived from the parties’ pleadings, M otion papers, and the Exhibits attached to petitioner’s Motion. They are stated solely for the purpose of deciding the Motion and not as findings of fact in this case. See Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff’d , 17 …
  2. T.C. Memo. 2007-327 — Gregory Eugene Thompson v. Commissioner
    IRCCourt RulingsOct 31, 2007
    … . To do so might suggest that these arguments have some colorable merit . Crain v . Commissioner , 737 F .2d 1417, 1417-1418 (5th Cir . 1984) . II . Does the 10-Percent Additional Tax Apply To the Distribution ? We next consider whether petitioner is liable for the 10percent additional tax on the early distribution fr…
  3. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    ny asserted abnormality under section 433 (b) (9) of the 1939 Code, was $770,547.83, $754,407.22, $670,214.40, and $497,443.65, respectively. OPINION. The first issue is whether the deduction claimed by the petitioner for officers’ compensation in the base period year ended January 31, 1947, entitles petitioner to cert…
  4. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010
    …ches stomach disorders) which may result from such . emotional distress ." H . Conf . ;Rept . . 104-737, at 301 n .56 (1996 ) , 1996-3 C .B . 741, 1041 . The text of the legislative history also contains this statement, which respondent has not referenced : . "Because all damages . received on account of physical injur…
  5. T.C. Memo. 2010-42 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsMar 4, 2010
    …se groundless and frivolous assertions warrant no further discussion . See Crain v . Commissioner , 737 F .2d 1417 (5th Cir . 1984) ("We perceive no need to refute these arguments with somber reasoning and copious citation of precedent ; to do so might suggest that these arguments have some colorable merit .") . We sus…
  6. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    services is $100,000. Assume that the district director proposes to increase D’s income by $100,000, but that the country in which F is located would have blocked payment in 196 5 for such services. If, prior to the first occurring of the events described in subdivisions (i), (ii), or (iii) of this subparagraph, D ele…
  7. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    IRCCourt RulingsSep 3, 1998
    …ept. 104-586 at 112 (1996), 1996-3 C.B. 331, 450; S. Rept. 104-281 at 80 (1996); H. Conf. Rept. 104-737 at 245-246 (1996), 1996-3 C.B. 741, 985-986. 7 Since the years involving the elective deferrals are fiscal years ending June 30, 1986, and June 30, 1987, only a portion of the employee contributions would have been i…
  8. 38 T.C. 312 — Hydro Molding Co. v. Commissioner
    IRCCourt RulingsMay 28, 1962related by meaning
    ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
  9. T.C. Memo. 2007-206 — Alex B. Rhodes, Jr. v. Commissioner
    IRCCourt RulingsJul 30, 2007
    …o so might suggest that these arguments have some colorable merit ." Crain v . Commissioner , - 8 - 737 F .2d 1417, 1417 (5th Cir . 1984) ; see Stelly v . Commissioner , 761 F .2d 1113, 1115 (5th Cir . 1985) ("It is clear beyond peradventure that the income tax on wages is constitutional") ; United States v . Romero , …
  10. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    acceptance, payments by the Government under the contract commenced. These payments included the following: July 21,1960 to Oct. 31,1960_ $563,232. 95 Nov. 1, 1960 to Oct. 31, 1961_ 1,541,579. 30 Nov. 1, 1961 to Oct. 31, 1962_ 386,034. 96 Total_ 2,490, 847. 21 For income tax purposes, the above payments were treated by…
  11. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007
    …ing accounts $881 n/a Savings accounts 53 n/a 401(k) plan account 107,449 -0Life insurance 4,975 $1,737 1998 Chevrolet Lumina 2,465 303 1991 Chevrolet S-10 450 -01988 Pontiac Grand Prix -0- -0House 200,000 164,155 Total 316,273 166,195 The reported value of the section 401(k) plan account reflected
  12. 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…
  13. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014
    …lan during the second quarter of 2006 and had paid its 2006 second quarter employment taxes. Id. at 737-739. Moreover, in Lofaren the Appeals officer summarily denied the taxpayer's requested payment plan solely upon the basis of his mistaken belief that accepting the plan was impossible under the Code and the regulati…
  14. T.C. Memo. 2005-67 — Laura D. Seidel v. Commissioner
    IRCCourt RulingsMar 31, 2005related by meaning
    now how these deductions were calculated. She did not substantiate such expenses. Therefore, this Court holds that such deductions are not allowed and respondent’s disallowance of such deductions is sustained. Due to our holding that petitioner has not substantiated any of the claimed Schedule C deductions for Port of …
  15. T.C. Memo. 2000-391 — Robert C. Geib v. Commissioner
    IRCCourt RulingsDec 28, 2000
    … 1989 901 -- 225 1990 1,897 -- 474 1991 3,160 -- 790 1992 4,809 -- 1,202 1993 6,660 -- 1,665 1994 8,737 -- 1,311 1998 1 -- $174,761 -- 1 For the taxable period ending January 15, 1998. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule refe…
  16. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    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…
  17. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
  18. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …ing a will is to ascertain the intent of the testator." R; see also Keisling v. Landrum, 218 S.W.3d 737, 741 (Tex. App. 2007). I also agree with the majority that if we did so, we would start with 23(...continued) sincere in initially claiming" they paid medical expenses with some of their assets). - 96 - the document …
  19. 102 T.C. 695; 102 T.C. No. 31 — Fazi v. Commissioner
    IRCCourt RulingsMay 19, 1994related by meaning
    e available to the corporation’s employees were the pre-TEFRA prototype plans, which did not meet the statutory requirements of tefra, defra, and REA. Even if the restated post-TEFRA prototype (which did meet the statutory requirements) was available, the corporation had not adopted the revised plan or paid the require…
  20. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 All dollar amounts are rounded to the nearest dollar. 3 Petitioner concedes that he is not entitled to the $24,248 alimony deduction that he claimed on his 2007 Federa…