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93 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2006-101 — Eugenie Denise Mitchell v. Commissioner
    IRCCourt RulingsMay 11, 2006
    …ined that petitibner was liable for the section 72(t) 10-percent additional tax in the amount of $1,742 on the total $17,422 in early distributions petitioner received in 2001 from her annuity and her SEP-IRA accounts. At trial, petitioner stipulated the applicability of the section 72(t) 10-percent additional tax on t…
  2. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  3. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996
    …anner that overrides the plain meaning of the statutory words. Huntsberry v. Commissioner , 83 T.C. 742, 747-748 (1984). No such contrary purpose has been shown here. Because we are satisfied that our analysis of section 4980A(e)(2) leads to the conclusion that the Retirement System
  4. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008
    …. The case before us is appealable to the Ninth Circuit, and under Golsen v. Commissioner , 54 T.C. 742 (1970), affd. 445 F.2d 985 (10th Cir. -391971), we do not enter decisions that will surely be reversed. Lardas v. Commissioner , 99 T.C. 490, 495 (1992). But I am confident that Wehrli would have been distinguishable…
  5. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    …in the instant case as to justify application of the "Golsen rule” (Golsen v. Commissioner, 54 T.C. 742, 756-758 (1970), affd. 445 F.2d 985 (10th Cir. 1971)). See, e.g., David Metzger Trust v. Commissioner, 76 T.C. 42, 72-74 (1981), affd. 693 F.2d 459 (5th Cir. 1982). We hold for petitioners on this issue. II. Excise T…
  6. T.C. Memo. 2005-67 — Laura D. Seidel v. Commissioner
    IRCCourt RulingsMar 31, 2005
    …urt must have some basis upon which an estimate may be made. Vanicek v. Commissioner , 85 T.C. 731, 742-743 (1985). Without such a basis, any allowance would amount to unguided largesse. Williams v. United States , 245 F.2d 559, 560-561 (5th Cir. 1957). Further, section 274(d) prohibits the estimation of expenses for t…
  7. 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…
  8. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    . 634, 648 (1994), affd. without published opinion 89 F.3d 856 (11th Cir. 1996). Section 402(b) (2) provides "the amount actually distributed" or made available to a distributee by a nonexempt employee trust must be included in the distributee's gross income pursuant to the annuity rules of section 72. See also sec. 1.…
  9. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …erein. See Hirasuna v. Commissioner, 89 T.C. 1216, 1224 (1987); Huntsberry v. Commissioner, 83 T.C. 742, 747-748 (1984). The legislative history of the statutes relevant to this case contains no evidence that Congress intended that there be any adjustment to account for inflation. As with the statutes, the regulations …
  10. 143 T.C. No. 11 — Dennis E. Bohner v. Commissioner
    IRCCourt RulingsSep 23, 2014related by meaning
    contributions would have been taxable. CSRS does not provide for the - 12 - acceptance of rollovers. Because the payment was not accepted as a pretax contribution, it is taxable. See Montgomery, 18 F.3d at 500. Therefore, section 408(d)(3) does not apply and the $17,832 petitioner withdrew from his Fidelity IRA must b…
  11. T.C. Memo. 1998-145 — Estate of Hilda Ashman, Deceased; Phillip Ashman, Personal Representative v. Commissioner
    IRCCourt RulingsApr 22, 1998
    …e inapplicable in tax deficiency cases appealable to that Circuit. Golsen v. Commissioner , 54 T.C. 742, 756-757 (1970), affd. 445 F.2d 985 (10th Cir. 1971). - 9 - Nor do we understand the Supreme Court decision in United States v. Brockamp , supra , to undermine the use of the duty of
  12. 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 …
  13. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    …ally lie - 11 - to the Court of Appeals for.the Eighth Circuit. See Golsen v. Commissioner, 54 T.C. 742 (1970), affd. 445 F.2d 985 (10th Cir. 1971). Respondent maintains that the issue was incorrectly decided by the Court of Appeals for the Ninth Circuit and challenges the claimed deductions on three grounds: (1) The r…
  14. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    payer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter 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 which is includible in gross income. - 9 - 5 See also …
  15. T.C. Memo. 2017-186 — Joe Pokawa & Nancy Fatoma v. Commissioner
    IRCCourt RulingsSep 21, 2017
    …evidence 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…
  16. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
  17. T.C. Memo. 1997-8 — Gary Benton & Karen Ruth Logsdon v. Commissioner
    IRCCourt RulingsJan 6, 1997
    …he Court of Appeals to which an appeal in this case would lie. See Golsen v. Commissioner , 54 T.C. 742 (1970), affd. 445 F.2d 985 (10th Cir. 1971). In Malbon v. United States , supra , the taxpayer retired under the CSRS in 1987 and elected the alternative annuity under 5 U.S.C. sections 8342(a) and 8343a, receiving a…
  18. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    or was the filing fee paid. See Rule 173(a). The Court ordered petitioners to file a proper amended petition and pay the filing fee by May 2, 2003. 13 Petitioners timely filed an amended petition with the Court and paid the filing fee. In the amended petition, petitioners disputed deficiencies determined for taxable ye…
  19. T.C. Memo. 2023-95 — Reynold Harvey v. Commissioner
    IRCCourt RulingsJul 25, 2023
    …ircuit . S ee § 7 48 2 (b)(1)(A). We thus follow its precedent. See Golsen v. Commissioner, 54 T.C. 742, 757 (1970), aff’d , 445 F.2d 985 (10th Cir. 1971). During 2018 petitioner was employed by the N ew York City Transit Authority. For that year it paid him wages o f $80,764, reporting that amount to him on Form W – 2…
  20. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…