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87 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2012-195 — Neil J. Yosinski v. Commissioner
    IRCCourt RulingsJul 12, 2012
    …total income of $167,014; 6. tax of $27*,505; 7. an additional tax pursvant to section 72(t) of $16,743; 8. total tax of $44,248; 9. federal income tax withheld of $20; 10. credit for federal tele hone excise tax paid of $60; and 11. an amount owed (inci uding a $2,093 estimated tax penalty) of $46,261.1 - · Petitioner…
  2. T.C. Summary Opinion 2011-16 — Paulette A. & Matthew D. Malena v. Commissioner
    IRCCourt RulingsFeb 24, 2011
    …r any other case. Respondent determined a deficiency in petitioners' 2007 Federal income tax of $15,743, as well as a section 6662(a) accuracy-related penalty of $3,132. After the dismissal of petitioner Matthew D. Malena,2 the issues for decision are: (1) Whether petitioner Paulette A. Malena (petitioner) received unr…
  3. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010
    …utional right to bring frivolous suits, see Bill Johnson's Restaurants, Inc. v. NLRB, 461 U.S. 731, 743 * * * (1983). People who wish to express displeasure with taxes must choose other forums, and there are many available. * * * [Coleman v. Commissioner, supra at 72.] In addition to advancing a frivolous or groundless…
  4. T.C. Memo. 2005-5 — Thomas G. Wright and Estate of Rosemary K. Wright, Deceased; Thomas G. Wright, Personal Representative v. Commissioner
    IRCCourt RulingsJan 13, 2005
    …er detriment. Hofstetter v. Commissioner , 98 T.C. 695, 700 (1992); Graff v. Commissioner , 74 T.C. 743, 761 (1980), affd. 673 F.2d 784 (5th Cir. 1982); Megibow v. Commissioner , T.C. Memo. 2004-41. The Supreme Court has held that the Government may not be estopped “on the same terms as any other litigant.” OPM v. Rich…
  5. 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…
  6. 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…
  7. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    …eration-skipping transfer tax payments). 5 or after April 1, 2020, and before July 15, 2020. Id. at 743– 44. Notice 2020- 23 specified, however, that it did not provide relief for the period for filing a petition if that period expired before April 1, 2020. Id. at 744 . On September 2, 2020, respondent filed the Motion…
  8. 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…
  9. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997
    …income tax: Year Deficiency Section 6662(a) 2 Accuracy-Related Penalty 1991 $46,801 $9,360 1992 104,743 20,949 1993 37,149 7,430 The issues remaining for decision are: (1) Does $268,027.48 of interest paid by petitioners during 1991 to the F.E. Hickman, DDS Orthodontics, Inc., Profit-Sharing Plan (Hickman corporation p…
  10. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988related by meaning
    e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted. An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
  11. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    one taxable year; at best, petitioner's assertion undermines the characterization of the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case. c. Frozen Deposit Rule Finally, although it is not clear whether petitioner relies on the special rule for frozen deposits f…
  12. T.C. Memo. 2025-1 — Matthew D. Hutcheson & Annette Hutcheson v. Commissioner
    IRCCourt RulingsJan 2, 2025
    …rain vehicles for their four minor children ; $11,702 for furniture ; $11,916 for fencing ; and $15,743 for Costco purchases . They also paid $47,822 to the U.S . Department of the Treasury and made approximately $10,000 in ATM withdrawals . Examples of p rofessional and resort-related expenses that petitioners paid wi…
  13. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  14. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    …nt.’” Hofstetter v. Commissioner , 98 T.C. 695, 700 (1992) (quoting Graff v. Commissioner , 74 T.C. 743, 761 (1980), affd. 673 F.2d 784 (5th Cir. 1982)). The traditional elements of equitable estoppel--all of which must be satisfied to invoke the doctrine--are: (1) A false representation or misleading silence by the pa…
  15. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  16. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsAug 6, 1996
    …le Year. The $57,139,406 consists of $48,395,987 of contributions to the Six Large CBA Plans and $8,743,419 to the 19 smaller plans. In addition, out of the total $96,890,058 deduction claimed by petitioner in the Current Taxable Year, respondent did not disallow $3,089,123 of contributions to certain profit-sharing pl…
  17. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    ith respect to our Opinion. In our Opinion, we held that petitioner may not deduct in a single taxable year contributions to 29 collectively bargained defined benefit plans made over a period of 20 (in some cases 19) months. In the Motion petitioner alleges that the Court erred in that this holding contradicts 20 years…
  18. T.C. Memo. 1998-52 — Robert E. Dunham v. Commissioner
    IRCCourt RulingsFeb 9, 1998
    …d Cir. 1977); Kelly v. Commissioner , T.C. Memo. 1987-352, affd. without published opinion 858 F.2d 743 (11th Cir. 1988). Petitioner's failure to file a valid tax return for 1989 was not due to reasonable cause. Rather, petitioner enclosed a letter with the return that stated he intentionally did not sign his return ba…
  19. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    75150 (Oct. 28, 2016); PTE 2016-10, 81 FR 75147 (Oct. 28, 2016); PTE 2012-08, 77 FR 19344 (March 30, 2012); PTE 2004-13, 69 FR 54812 (Sept. 10, 2004). Back to Citation 38.  On December 12, 2018, Korea's Seoul High Court for the 7th Criminal Division (the Seoul High Court) reversed the Korean Court's decision and declar…
  20. T.C. Memo. 2017-186 — Joe Pokawa & Nancy Fatoma v. Commissioner
    IRCCourt RulingsSep 21, 2017
    …ence providing a sufficient basis for making an estimate. Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). Without such basis, any allowance would amount to unguided largesse. Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957). I. Schedules C Respondent disallowed all of petitioners' claimed Schedule C d…