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61. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
62. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011
    T.C. Summary Opinion 2011-113 UNITED STATES TAX COURT GAIL MARIE WATSON, Petitioner v. COMMISSIONER- OF INTERNAL REVENUE, Respondent Docket No. 14769-10S. Filed September 28, 2011. Gail Marie Watson, pro se . . .. Ryan M. Wyzik, for respondent. . DAWSON, Judge: The petition' in this case was filed pursuant to the provi…
63. T.C. Memo. 2025-7 — Sonji Marie Mosley v. Commissioner
    IRCCourt RulingsJan 22, 2025
    …icates that the foreclosure on the South Carolina land resulted in a long-term capital loss of $135,113. To be sure, had this $135,113 loss been reported and claimed correctly, petitioner might have been entitled to a long-term capital loss deduction of $3,000 for 2018 pursuant to section 1211(b). However, because she …
64. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    payer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. - 9 - 5 See also …
65. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …l circumstances, we have returned to the core responsibility of experts : to aid the trier of fact. 113 method, which produced a value of $6.996 billion, 112 and his lower-bound unspecified method applying the 1995 cost sharing regulations, which produced a value of $4.834 billion. See Temp. Treas. Reg. § 1.4827T(g)(4)…
66. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    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…
67. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …,375 $24,188 $24,188 Money Fund 188,657 188,657 - Repo Account 184,155 184,155 - Mortgage 76,225 38,113 38,113 Mortgage 40,000 40,000 - Contract 34,433 34,433 - Note-1 26,815 26,815 - Note-2 2,300 2,300 - Note-3 80,000 80,000 - Note-4 17,500 17,500 - IRA-Kemper 9,000 9,000 - IRA-Kemper 8,250-8,250 IRA-1st Fla. 2,500 2,…
68. 85 T.C. 1024; 85 T.C. No. 59 — Greene v. Commissioner
    IRCCourt RulingsDec 24, 1985related by meaning
    terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
69. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …n 2041(b)(1)(A) or 2514(c)(1), Internal Revenue Code of 1986 * * * - 39 - Tex. Prop. Code Ann. sec. 113.029(b)(1) (2014).27 Consequently, Mrs. Melasky's discretion to distribute is limited under Texas law, which looks to the meaning of "health, education, support, or maintenance" as defined under section 2041(b)(1)(A) …
70. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
71. 78 T.C. 395; 78 T.C. No. 27 — Sutherland v. Commissioner
    IRCCourt RulingsMar 9, 1982
    … plan. * * * [Sec. 1.401-l(b)(2), Income Tax Regs. Emphasis added.] In Rev. Rul. 69-25, 1969-1 C.B. 113, the Service considered this regulation in some detail. That ruling states that when a newly established plan "is first considered for a determination letter” by the Service, the plan is presumed to have been establi…
72. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
73. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …hour on the 2004 examination. In this one hour, as she documented, she talked with the Goldbergs' - 113 - [*113] representative, Dubow (the son), to request--as she already had done in the September 2007 IDR and by phone and email to Goldberg--information about the Goldbergs' bases in their shares and debt of their who…
74. T.C. Summary Opinion 2005-80 — Harald Berrey v. Commissioner
    IRCCourt RulingsJun 9, 2005related by meaning
    . 213 shall be deemed paid for by a portion of petitioner’s withdrawal from his thrift savings plan and are therefore excepted from the additional tax under sec. 72(t). Respondent further concedes that petitioner’s filing status is married filing jointly. Respondent determined a deficiency in petitioner’s Federal incom…