IRCCourt RulingsMar 25, 2013
…ifications of each expert and all other evidence in the record. See Parker v.
Commissioner, 86 T.C. 547, 561 (1986). While we may accept an expert opinion
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[*9] in its entirety, Buffalo Tool & Die Mfg. Co. v. Commissioner, 74 T.C. 441,
452 (1980), we may be selective in the use of any part of such opinion or rejec…
IRCCourt RulingsOct 8, 2003related by meaning
ng this amount. Subsequently,
J.D. merged into Clarkston pursuant to section 368, and filed a
final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the
final return year of J.D. eliminated by book entry as a result of
the merger.
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Discussion
Respondent’s …
IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
IRCCourt RulingsFeb 9, 2023
…he computation below:
a. Total cost of goods sold of products
m anufactured by 3M Brazil (from Form 5471,
Sch. C, line 2) $332,547,422
Cost of goods sold (other than raw m aterials)
purchased from:
b. U.S. affiliates (from Form 5471, Sch. M ,
Line 10(b)+(c)) (42,966,307)
c. Foreign affiliates (from Form 5471, Sch. M,
L…
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
IRCCourt RulingsJul 5, 2011
…ffice
or employee. McMahan v. Commissioner, 114 F.3d 366, 369 (2d Cir. 1997), affg. T.C. Memo. 1995-547; see also Gagliardi v.
Commissioner, T.C. Memo. 2008-10. Reliance on a mistaken legal
opinion of a competent tax adviser that it was unnecessary to
file a return also constitutes reasonable cause. McMahan v.
"While t…
IRCCourt RulingsMay 22, 2025
… reliable principles and methods to
the facts and data. See, e.g. , Parker v. Commissioner, 86 T.C. 547, 561
(1986) (citing Fed . R. Evid. 702). We have drawn conclusions relying on
their testimony , but we have used a large shaker of salt to compensate
for the ir advocacy.
Operating within the confines of the regulati…
IRCCourt RulingsJan 16, 2020related by meaning
is to be
-6included in gross income in the year in which the payment is received
rather than in the years to which the payment is attributable, to the extent that application of the formula results in a taxable amount.
The election merely provides an alternative method of applying the
formula to determine the taxable p…
IRCCourt RulingsDec 19, 2000
…r. See, e.g.,
Money v. Commissioner
, 89 T.C. 46, 48 (1987); Burbage v.
Commissioner
, 82 T.C. 546, 547 n.2 (1984), affd. 774 F.2d 644
(4th Cir. 1985); Zimmerman v. Commissioner
, 67 T.C. 94, 104 n.7
(1976).
determination that petitioners were not entitled to a 1982
investment tax credit that they claimed was attributa…
IRCCourt RulingsOct 20, 2003related by meaning
result apparently so at
odds with accepted tax policy.” Darby v. Commissioner
, supra
at
68.
We find that petitioner did not have a basis in the 1999 distribution from his section 401(k) plan, and that petitioner
properly included the full distribution in his 1999 gross income.
Accordingly, we hold that petitioner is l…
T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner IRCCourt RulingsJun 17, 1998
…ve necessity, and their general use
was approved by the courts. Simpson v. United States
, 252 U.S.
547, 550-551 (1920); Estate of Fabric v. Commissioner
, 83 T.C.
932, 941 (1984). As a result, these administrative actuarial
tables were regularly applied in valuing contingent property
interests given that they "afford …
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsJul 24, 1996
… fiscal 1987 and arrived at expenses of
$2,093,462. Dorn then subtracted employee contributions of
$547,110 and $6,402 related to key employees. (Plans covering
key employees must be funded separately. See sec. 419A(d).) The
result of the above calculations was $1,539,950. At this point,
Dorn consulted with Harry A. Do…
IRCCourt RulingsJun 9, 1977
…ro Rental v. Commissioner, 64 T.C. 331, 336-337 (1975); cf. Poirier & McLane Corp. v. Commissioner, 547 F.2d 161 (2d Cir. 1976), revg. 63 T.C. 570 (1975), cert. applied for 4/11/77. However, in this situation, it is not clear what legal significance attaches to the notice requirement. Cf. Precision Industries, Inc. v. …
IRCCourt RulingsApr 12, 1979
…s . 675.00 2 months
G. Hargrove . 3,676.60 8 months
K. Maupin . 1,400.00 1 year 2 months
S. Smith . 547.50 1 month
W. Stotts II . 4,096.20 9 months
C. Taggart . 1,717.40 6 months
H. Willcox . 1,659.99 1 year 3 months
T. Kelso . 481.00 1 month
J. Houston . 681.00 2 months
$19,027.19
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.
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[*3] to deduct a net operating loss (…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsNov 10, 1998related by meaning
tstanding rollover involved in
this case. Accordingly, the amount of excludable basis in the
instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is
$1,950 and the denominator of which is $1,374.53 plus $6,100,
resulting in an amount excludable of $1,591.40.…
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
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[…
IRCCourt RulingsOct 19, 1981
…ter S Taxation 67-77 (1974); W. Painter, Corporate and Tax Aspects of Closely Held Corporations 523-547, 568-571 (2d ed; 1981); Banoff, "Reducing the Income Tax Burden of Professional Persons by Use of Corporations, Joint Ventures, Subpartnerships and Trusts,” 58 Taxes 968 (1979); Battle, "The Use of Corporations by Pe…