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94 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2001-146 — Michael T. Chappell v. Commissioner
    IRCCourt RulingsJun 20, 2001
    …470 1,578 Office expense –- 1,821 Rent 3,350 3,360 Repairs and maintenance 339 350 Supplies 2,875 2,718 Taxes and licenses 285 245 Utilities 6,487 6,987 Wages 9,500 9,879 - 8 - H. Respondent’s Audit and Determination Respondent’s tax auditor, Shirley Todd (Todd), audited petitioner’s 1994 and 1995 income tax returns. P…
  2. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * 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 w…
  3. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
  4. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    IRCCourt RulingsMay 9, 2002related by meaning
    ven report the distributions. the clear intent of Congress to prevent voluntary withdrawals, we decided that the penalty was inapplicable. Id. at 291. Petitioners’ reliance on Larotonda v. Commissioner , supra , is misplaced. Here, respondent did not levy on the retirement accounts. Petitioners made voluntary withdrawa…
  5. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
  6. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    lating to petitioners' loan, 10.5 percent is the fair market interest rate. V. Addition to Tax Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to file Form 5330 for each taxable year, or portion thereof, in the taxable period. Sec. 6011; sec. 54.6011-1(…
  7. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015
    …xpenses that he had claimed), aff'd in relevant part sub nom. Keller v. Commissioner, 568 F.3d 710, 718 (9th Cir. 2009). Petitioners conceded this issue at trial. - 27 - [*27] Atchison v. Commissioner, T.C. Memo. 2009-8, 97 T.C.M. (CCH) 1034, 1036 (2009). Petitioners do not challenge the existence or amount of the unde…
  8. IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
  9. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …746,184 1,752,870 6/30/87 94,305,548 962,317 95,267,865 4,098,466 6/30/88 112,993,217 1,725,585 114,718,802 6,871,287 6/30/89 143,612,396 4,476,187 147,088,583 9,650,154 6/30/90 159,302,147 2,822,959 162,125,106 11,430,723 6/30/91 149,671,091 2,045,944 151,717,035 2,805,387 On April 1, 1974, BI and Mr. Schoenecker ente…
  10. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998related by meaning
    titioner, WE 7, and - 18 - 4 The complaint filed in the Superior Court indicates that the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987. the Guardian Construction Co., Inc., as corporate partners of Estes Co. Petitioner was identified as a partner…
  11. T.C. Memo. 2021-105 — Sherrie L. Webb v. Commissioner
    IRCCourt RulingsAug 31, 2021
    …lled record rule applies to CDP cases before this Court. See Keller v. Commissioner , 568 F.3d 710, 718 (9th Cir. 2009), aff’g in part T.C. Memo. 2006- 166, and aff’g in part, vacating in part decisions in related cases; Murphy v. Commissioner, 469 F.3d 27 (1st Cir. 2006), aff’g 125 T.C. 301 (2005); Robinette v. Commis…
  12. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014
    …istrative record (i.e., the administrative record rule). S_ee Keller v. Commissioner, 568 F.3d 710, 718 (9th Cir. 2009), aff'g T.C. Memo. 2006-166.4 4Recently, the Court of Appeals for the District of Columbia Circuit held in Byers v. Commissioner, 740 F.3d 668, 675-677 (D.C. Cir. 2014), aff'g T.C. Memo. 2012-27, that …
  13. T.C. Memo. 2019-124 — William Elias Rosenberg v. Commissioner
    IRCCourt RulingsSep 19, 2019related by meaning
    e. Because petitioner raises only a legal issue, we decide whether he is liable for the deficiency without regard to the burden of proof. II. Analysis Gross income generally includes distributions from an IRA under the provisions of section 72. Sec. 408(d); see Sears v. Commissioner, T.C. Memo. 2010-146. Section 72(t)(…
  14. 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…
  15. 60 T.C. 227; 60 T.C. No. 27 — Tobey v. Comm'r
    IRCCourt RulingsMay 17, 1973related by meaning
    was “earned income” within the ambit of section 911 (b) and is excludable from gross income to the extent of $25,000 per year under section 911 ('a). Petitioner has claimed overpayments of $5,517 for 1965 and $7,040.82 for 1966. As to the first amount, it is stipulated that the petitioner overstated his gross income f…
  16. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  17. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  18. 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…
  19. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025
    …n a petition for review un der 26 U.S.C. § 6330(d)(1).”); cf. Keller v. Commissioner, 568 F.3d 710, 718 (9th Cir. 2009), aff’g in part T.C. 8 P ursuant to Rule 93(a), the parties can stipulate either “the entire administrative record . . . or so much of that record as either party may deem necessary for a complete disp…
  20. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are rounded to the nearest dollar. 2Petitioners conceded that they were not entitled to exclude from gross income rental income of $4,920 they received in 2007. - 3 - [*3] to deduct a net operating loss (…