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 …
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…
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…
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…
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…
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…
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…
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…
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 , …
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…
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
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…
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…
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 …
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…
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 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…
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 …
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…
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…