IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977related by meaning
r, 68 T.C. 826 (1977).
In view of concessions made by the parties and our conclusions on the disputed issues,
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated.
Variances between this schedule and Form 4848 reflect persons …
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
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsMay 14, 2009
…ds to
substantiate the expenses . Secs . 162(a ), 6001 ; Deputy v . du Pont , 308 U . S . 488 , 495-496 ( 1940 ) ; Hradesky v . Commissioner , 65
T .C . 87 , 90 (1975), affd . 540 F . 2d 821 ( 5th Cir . 1976) ; sec .
1 .6001-1 ( a), Income Tax Regs .
- 11 -
Aside from brief self-serving testimony offered by Mr .
Basaly…
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…
IRCCourt RulingsAug 30, 1999related by meaning
ons are includible in petitioner's gross income for 1995. Petitioner
contends that they are not. In support of that contention,
petitioner argues that there was gross negligence by the [Family] court and my
ex-wife's lawyer that caused the money to be removed
from the IRA. * * *
* * * * * * *
This was a forced withdraw…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…
IRCCourt RulingsJun 28, 2010
…, such evidence as
perceived by the patient" . The Sloane-Dorland Annotated MedicalLegal Dictionary 496 (Supp . 1992) . A "symptom" is distinguished
from a "sign defined as "any objective evidence of a disease,
i . .e ., such evidence as is perceptible to the examining physician
,
as opposed to the subjective sensation…
IRCCourt RulingsJan 12, 1998related by meaning
nice Spetz 8,724
15342-96 Robert C. and Mary D. Borman 16,462
17606-96 Nurit Haramgaal 11,405
17607-96 John S. Husmann and Elinor C. MacKinnon 4,606
1 A notice of deficiency was issued to Alice M. Johnson and her
husband Duaine E. Johnson. Mr. Johnson died on Sept. 1, 1994. An
estat e was not opened for him. Alice M. J…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…nd other income, designated “Trustees Fees” of $200 ,
resulting in a n adjusted gross income of $56,496 . On Sche dule C, Profit
or Loss F rom Business, Mr. Aldridge listed his principal business or
profession as “Advisor: Family Trust , ” and reported gross receipts or
sales of $500 and car and truck expenses of $3,13…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
IRCCourt RulingsMar 24, 2000
…context of the particular business out of which it arose. See Deputy v.
du Pont
, 308 U.S. 488, 495-496 (1940). A taxpayer’s general
statement that his or her expenses were incurred in pursuit of a
trade or business normally is not sufficient to establish that
the expenses had a reasonably direct relationship to that t…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-263
UNITED STATES TAX COURT
RICHARD J. MONTGOMERY AND ADELE S. MONTGOMERY, Petitioners v
.
COMMISSI…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsMar 1, 2016
…IRS is entitled to correction of an error, if merited. See, e.g.,
Chertkof v. Commissioner, 66 T.C. 496, 503 (1976) ("The Government's 'fault' in
taking its first view--at least if it was done in good faith--was not to prevent it
from collecting the revenue or to absolve the taxpayer from all tax on the item."),
a_f[d,…
IRCCourt RulingsFeb 10, 1997related by meaning
e within the parameters
spelled out in section 404(a)(6), may be deducted in the prior
year, but only
if
they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's
Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
IRCCourt RulingsNov 10, 2011
…unds
in five separate checks, four3 of which were for $9,000 each and
the fifth of which was for $9,496.50.
2The substitute Form W-4P differs greatly from the IRS'
original form. The original Form W-4P is a fourtpage document
consisting of two pages of instructions and a twp-page worksheet
to calculate the appropriate …
IRCCourt RulingsMar 31, 1970related by meaning
OPINION
Quealy, Judge:
Respondent determined a deficiency in income tax of petitioner for the taxable year September 10, 1965, to June 80, 1966, in the amount of $618.41. The sole issue for decision relates to the deductibility of a payment of $2,000 made to the widow of a former officer of Utilities Engineering & Mana…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…