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61. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
62. T.C. Memo. 1999-161 — Roblene, Inc. v. Commissioner
    IRCCourt RulingsMay 13, 1999
    …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. Contributions made by the employer to a plan of deferred compensation to the extent that, before the application of the section 415 limitations to that plan, the contribut…
63. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    issues 166 F.3d 1201 (2d Cir. 1998). Respondent counters that there are no statutory exceptions to the early withdrawal tax which apply in the instant case and that the cases relied on by petitioner are distinguishable from the present case and therefore are not controlling here. We first address whether there are any …
64. T.C. Memo. 2022-3 — John M. Larson v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …e share s of Morley income for 1999, 2000, and 2001 from zero to $8,915,329, $4,265,220, and $2,790,737, respectively (i.e., 33.33% of Morley’s reported income for the relevant taxable years) . 7 The IRS also 6 Mr. Larson, through his counsel, filed protective refund claims on Forms 1040X, Amended U.S. Individua l Inco…
65. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025
    …ds of cases, and we will not dignify his position with further response. See Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) (per curiam) (“We perceive no need to refute these arguments with somber reasoning and copious citation of precedent . . . .”); see also Wnuck , 136 T.C. at 501 – 13 (explaining why co…
66. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    tion to be carried out with respect to whether the tax imposed by section 4975 of Title 26 should be applied to any person referred to in the request. Because our Rules do not recognize a motion to limit a deficiency determination, petitioners’ request should have been cast as a motion for partial summary judgment unde…
67. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997
    …dition to Tax Sec. 6654 1987 $24,520 $4,748 $361 1988 20,939 3,124 738 1990 20,349 3,925 998 1991 6,737 1,460 331 1992 4,554 1,105 192 Petitioner Joan E. Murtaugh: Year Deficiency Addition to Tax Sec. 6651(a) Addition to Tax Sec. 6654 1987 $2,075 $100 $0 1988 1,901 29 0 1992 3,098 168 0 Unless otherwise noted, all sect…
68. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…
69. T.C. Memo. 2020-151 — Scott Lashua v. Commissioner
    IRCCourt RulingsNov 9, 2020
    …ner's other arguments are frivolous and warrant no further discussion. S_e_e Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) ("We perceive - 6 - [*6] 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 meri…
70. 64 T.C. 331 — Aero Rental v. Commissioner
    IRCCourt RulingsMay 29, 1975related by meaning
    r’s refusal cannot be justified on the ground that the ruling was requested and granted before the enactment of the revised version of section 401(b). Here, we have compelling reasons for holding this plan qualified for the years in issue: The employer brought the plan to the attention of IRS — there was no withholding…
71. T.C. Memo. 1999-240 — Marty M. & Marilee D. Morin v. Commissioner
    IRCCourt RulingsJul 22, 1999
    …nt; to do so might suggest that these arguments have some colorable merit." Crain v. Commissioner , 737 F.2d 1417, 1417 (5th Cir. 1984). Accordingly, we sustain respondent's determination that these amounts are income. - 5 - 2 Respondent, in the separate notices of deficiency sent to Mr. Morin and Mrs. Morin, determine…
72. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    nd contribution, made during December 1986, would be deductible in 1986, because that contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986. Accordingly, petitioner argues, the regulation contradicts the plain language of section 419 and is invalid. Petiti…
73. 66 T.C. 324 — Bianchi v. Commissioner
    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…
74. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
75. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998
    …nt; to do so might suggest that these arguments have some colorable merit." Crain v. Commissioner , 737 F.2d 1417, 1417 (5th Cir. 1984). Section 61(a) defines an individual's gross income as "all income from whatever source derived". Respondent determined that compensation for services, gains derived from dealings in -…
76. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    articipants, Harold Breslow and Robert Levine, received their full benefit and petitioner signed an irrevocable waiver of his rights to Plan benefits. We reject petitioner's argument. Examining the record, we find no documentary evidence that all rank and file employees were paid their full vested interest, especially …
77. 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…
78. 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…
79. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
80. 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…