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61. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    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…
62. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
63. 98 T.C. 283; 98 T.C. No. 23 — Aronson v. Commissioner
    IRCCourt RulingsMar 18, 1992related by meaning
    JACOBS, Judge: This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A and Rule 180. The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Special Trial Judge: In a notice of deficiency …
64. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
65. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ess doctrine, courts may invalidate laws if "'men of common intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor - - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945 F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra addresses tran…
66. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    nd contribution, made during December 1986, would be deductible in 1986, because that contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986. Accordingly, petitioner argues, the regulation contradicts the plain language of section 419 and is invalid. Petiti…
67. 127 T.C. No. 1 — Charlotte & Charles T. Gee v. Commissioner
    IRCCourt RulingsJul 24, 2006related by meaning
    petitioners' Federal income tax for 2002 and determined that petitioners are liable for the accuracy-related penalty under section 6662(a)' for 2002 . There are two issues for decision . The first issue is whether a $977,888 distribution petitioner Charlotte Gee (petitioner) received in 2002 from an individual retireme…