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61. T.C. Memo. 2014-227 — Brian K. Brinkley v. Commissioner
    IRCCourt RulingsOct 30, 2014related by meaning
    T.C. Memo. 2014-227 UNITED STATES TAX COURT BRIAN K. BRINKLEY, Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7367-13. Filed October 30, 2014. William R. Leighton, for petitioner. Roberta L. Shumway, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Respondent determined a $36…
62. T.C. Memo. 2000-266 — Lester L. & Susan P. Samford v. Commissioner
    IRCCourt RulingsAug 24, 2000
    …uendo based on innuendo that petitioners argue here. See Estate of Durkin v. Commissioner , 99 T.C. 561 (1992). An appropriate order denying petitioners’ Motion to Dismiss for Lack of Jurisdiction will be issued .
63. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    ent with the intent of DEFRA, and because it permissibly fills a gap created by sections 419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is not impermissibly broader than sections 419 and 419A and, accordingly, we hold that it is valid. Chevron…
64. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    …ion 163 (relating to interest), or (ii) deduction for dividends paid (within the meaning of section 561). (B) Stock of certain regulated investment companies.--Any amount paid or incurred 'in connection with the redemption of any stock in a regulated investment company which issues only stock which is redeemable upon t…
65. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
66. 29 C.F.R. § 2570.8 — Summary decision.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.41 of this title.
67. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    Indus., Inc. , 508 U.S. 152 (1993), but asserts that the Court's decision there applied only to unencumbered property contributed in satisfaction of a funding obligation. Here, petitioner asserts, he transferred unencumbered property to repay a loan. Petitioner asserts that repaying the loan was more beneficial to the …
68. T.C. Memo. 2001-71 — Clayton W. Plotkin v. Commissioner
    IRCCourt RulingsMar 23, 2001related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 2001-71 UNITED STATES TAX COURT CLAYTON W. PLOTKIN, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent …
69. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute. II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
70. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    prohibited transaction. We do not decide the issue, however, because there remain genuine issues of material fact precluding partial summary judgment. Under Rule 121(b), summary judgment is appropriate “if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together w…
71. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002
    …fit or Loss from Business, net income -0- 15, 305 -0- (5, 373) Deductions Medical 2,769 -0- 1,291 3,561 Mortgage interest 6, 989 -0- 6, 962 -0Charitable contributions 6,070 4,489 150 4,152 Taxes 617 -0- 175 · -0Miscellaneous itemized 70 -0- 75 -0Other Sec. 72(t) additional tax -0- 764 -0- 2,566
72. T.C. Summary Opinion 2007-168 — Cheryl Kunsman v. Commissioner
    IRCCourt RulingsSep 24, 2007
    …r . 1963) ; Peirce v . Commissioner , T .C . Memo . 1982-154 . In Shea v . Commissioner , 780 F .2d 561, 567 (6th Cir . 1986), affg . in part and revg . in part T .C . Memo . 1984-310, a joint return was held invalid as to the taxpayer where the attorney and tax return preparer signed the taxpayer's name to the return,…
73. U.S. Tax Court — John C. Armbrust v. Commissioner
    IRCCourt RulingsJan 19, 2010related by meaning
    section 72(t), imposing an-additional tax of "10 percent of the portio n To discourage individuals from taking premature I include premature distrib u the taxpayer, sec . 72(t) .(2 being disabled, sec . 72(t) insurance premiums for the unemployment, sec . 72(t)( 2 In 1997, as part of t 105-34, secs 203, 303, 11 more ex…
74. T.C. Memo. 1996-264 — Allan R. & Joan K. Powell v. Commissioner
    IRCCourt RulingsJun 11, 1996
    …-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; see Wheeler v. Commissioner , T.C. Memo. 1993-561; see also Sites v. United States , 75 AFTR 2d 95-2503, 95-1 USTC par. 50,280 (D. Md. 1995). Thus, as a consequence of aggregating the Retirement System and the Pension System, we have held that a taxpayer's transfer …
75. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    er for calendar year 1993 except that the reference to "20% reduction" was changed to "50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA 1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this connection, prior to its amendment by OBRA …
76. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …s a sham and disregarded for Federal income tax purposes. Frank Lyon Co. v. United States, 435 U.S. 561 (1978); Rice's Toyota World, Inc., 81 T.C. at 196. The economic substance of a transaction, rather than its form, controls. Frank Lyon Co., 435 U.S. at 583-584; Derr v. Commissioner, 77 T.C. 708 (1981). The U.S. Cour…
77. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred. EMPLOYEE PLANS T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
78. T.C. Memo. 2017-125 — Jeremy Ray Summers v. Commissioner
    IRCCourt RulingsJun 26, 2017related by meaning
    e requirements of the QDRO provisions must be "rigidly observed" because they "relate to the substance or essence of the statute"). We have con- - 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help minimize stress on his soon-to-be ex-wife disabled him from satisfying the statutor…
79. 115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner
    IRCCourt RulingsNov 9, 2000related by meaning
    115 T.C. No. 33 UNITED STATES TAX COURT SHERWIN-WILLIAMS COMPANY EMPLOYEE HEALTH PLAN TRUST, KEY TRUST COMPANY OF OHIO, TRUSTEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21333-97. Filed November 9, 2000. Trust (T), a tax-exempt voluntary employees’ beneficiary association described in sec.…
80. 29 C.F.R. § 4907.171-4907.999 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]