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89 documents · 0.41sAllIRCERISAPBGCJoint Board
  1. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994related by meaning
    years in issue in respect of a reserve for postretiremerit medical and life insurance benefits within the meaning of section 419A(c)(2). C. Conclusion Based on the foregoing, we hold that petitioner’s account limit under section 419A(c)(l) attributable to claims incurred but unpaid for medical benefits is $3,876,709 an…
  2. 29 T.C. 22 — Loeb v. Commissioner
    IRCCourt RulingsOct 11, 1957
    …d by the value of the interest transferred or which ceases at death. In Heiner v. Donnan, supra, at 322, the Supreme Court said: “The thing taxed is the transmission of property from the dead to the living. It does not include pure gifts inter vivos” Although the language quoted above seems to support the position take…
  3. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …948,014 165,000 62 2,363,755 71,633 45 1,277,687 54,811 45 977,641 170,000 62 2,435,384 74,170 45 1,322,938 56,472 45 1,007,267 175,000 62 2,507,012 76,352 45 1,361,876 58,133 45 1,036,893 - 13 - In determining the permissible normal retirement benefit under the plan
  4. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  5. 39 T.C. 362 — Wilson v. Commissioner
    IRCCourt RulingsNov 6, 1962related by meaning
    ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated. Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act. Thls section was originally desi…
  6. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  7. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    … form they might have chosen, whichever is less. Television Indus., Inc. v. Commissioner , 284 F.2d 322, 325 (2d Cir. 1960), affg. 32 T.C. 1297 (1959). - 17 - Petitioners' assertion that they used Milo Chapman and David Christie as intermediaries to avoid the excise tax of section 4975 is untenable. Petitioners now are…
  8. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  9. 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…
  10. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996
    …sioner v. Groetzinger , 480 U.S. 23, 28 (1987); see also Addison v. Holly Hill Fruit Prods., Inc. , 322 U.S. 607, 618 (1944). Moreover, words in a revenue act generally are interpreted in their "'ordinary, everyday senses'". Commissioner v. Soliman , 506 U.S. 168, 174 (1993) (quoting Malat v. Riddell , 383 U.S. 569, 57…
  11. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020
    …ar Deficiency sec. 6662(a) 2007 $213,621 $42,724 2008 13,244 2,649 2009 43,973 8,795 2010 56,612 11,322 Clark J. Gebman and Rebecca Gebman (Docket No. 13905-16) Penalty Year Deficiency sec. 6662(a) 2012 $20,340 $3,668 2013 34,375 6,475 2014 15,881 2,890 After concessions,2 the issues for decision are whether: (1) petit…
  12. T.C. Memo. 1996-231 — Charles E. King v. Commissioner
    IRCCourt RulingsMay 22, 1996
    …nd deducted business expenses in the aggregate amount of $11,272.26, resulting in a net loss of $10,322.26. In particular, petitioner claimed deductions for utilities of $351.22 and "Repairs and maintenance of office in home" of $161.32, each representing 20 percent of the total utility and maintenance cost of petition…
  13. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010
    …etirement pay (MRP). For 2004 the gross amount petitioner was entitled to receive as his MRP was $1,322 per month.3 However, petitioner executed a Veterans Administration waiver pursuant to which he waived receipt of $205 each month.4 The Defense Finance and Accounting Service (DFAS) is the agency responsible for disbu…
  14. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  15. T.C. Summary Opinion 2007-187 — Wayne Smith v. Commissioner
    IRCCourt RulingsNov 1, 2007
    …at there is a genuine issue for trial ." Rule 121(d) ; Celotex Corp . v . Catrett , 477 U .S . 317, 322 (1986) . The petition was filed pursuant to section 6330(d), which provides for Tax Court review of the Commissioner's administrative determinations to proceed with the collection of
  16. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    IRCCourt RulingsNov 21, 2007
    …d and earned dividend income in the amount $509 .90 for the -10remaining 12 days of November and $1,322 .35 for the month of December . Thus, through the end of 1998, petitioner's IRA earned dividend income in the aggregate amount of $1,832 .25 on the net proceeds realized from the sale of his J .D . Edwards & Co . sto…
  17. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    ement of this title, including all rules and regul ations as may be necessary by reason of any alteration of law in relation to internal revenue.” 108 Section 7805(b) of the Internal Revenue Code of 1954, 68A Stat. at 917, was the provision in the Internal Revenue Code of 1954 that was analogous to section 3791(b) of t…
  18. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
  19. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  20. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005
    …s, P.C. v. Wells , 538 U.S. 440, 444-445 (2003); Nationwide Mut. Ins. Co. v. Darden , 503 U.S. 318, 322-323 (1992); Weber v. Commissioner , 60 F.3d 1104, 1110-1111 (4th Cir. 1995), affg. 103 T.C. 378 (1994); Air Terminal Cab, Inc. v. United States , 478 F.2d 575, 578 (8th Cir. 1973); Profl. & Executive Leasing, Inc. v.…