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61. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    …red by the Joint Committee on Taxation (the Blue Book); privatd letter rulings and technical advice memoranda issued after October 31, 1976; actions on decisions and general counsel memoranda issued after March 12, 1981 (as well as general counsel memoranda published in pre-1955 volumes of the Cumulative Bulletin); Int…
62. 95 T.C. 415; 95 T.C. No. 30 — Albertson's, Inc. v. Commissioner
    IRCCourt RulingsOct 9, 1990
    …ad sense the term means a contract for the use of money. * * * [Black’s Law Dictionary 167 (5th ed. 1979).] Forbearance. Act by which creditor waits for payment of debt due him by debtor after it becomes due. * * * A delay in enforcing rights. * * * [Black’s Law Dictionary 580 (5th ed. 1979).] Rent. Consideration paid …
63. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    ng warned by the Court and after having received notice from the Court in a prior case. 6 On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's position is both frivolous and groundless. Accordingly, we exercise our discretion and award a penalty t…
64. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980
    OPINION Hall, Judge: Petitioner Jorj Judd (Jorj) is a cosmetologist. On March 29, 1979, respondent mailed a statutory notice asserting a deficiency in petitioners’ 1976 joint tax return of $1,317. Part of the deficiency related to $2,300 in unreported tips allegedly received by Jorj during the course of her 1976 employ…
65. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    … T.C. 85, 101 (2004); Keller v. Commissioner, 568 F.3d 710, 718 (9th Cir. 2009), aff'g in part T.C. Memo. 2006-166, and aff'g in part, vacating in part decisions in related cases. Goldberg resided in Illinois when he filed his petition. Therefore our decision will not be appealable to the First, Eighth, or Ninth Circui…
66. 78 T.C. 812; 78 T.C. No. 57 — Service Bolt & Nut Co. Profit Sharing Trust v. Commissioner
    IRCCourt RulingsMay 20, 1982
    …error. A statutory notice is now being prepared and will be issued at an early date.” On January 8, 1979, the Cincinnati Service Center abated the prior assessments of tax and penalties and so notified each petitioner. On November 1, 1979, statutory notices of deficiency were issued to each of petitioners. On December …
67. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
68. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…
69. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997
    …ncome generating activity. Williams v. Commissioner , 999 F.2d 760, 763 (4th Cir. 1993), affg. T.C. Memo. 1992-153; Anastasato v. Commissioner , 794 F.2d 884, 886-887 (3d Cir. 1986), vacating and remanding T.C. Memo. 1985-101; Jackson v. Commissioner , 73 T.C. 394, 401 (1979). The Commissioner need only provide a minim…
70. 73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner
    IRCCourt RulingsOct 30, 1979related by meaning
    unts of all participants in the profit-sharing plan as restated pursuant to the proposed amendment as if it had been in effect from 1972 through 1975. The corporate resolution adopted, effective May 1, 1977, a money purchase pension plan to which petitioner's contributions would be "10% of the annual compensation of ea…