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61. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013
    … that had paid compensation to Mr. Ellis in 2005, was thus owned primarily by his IRA. II. Tax Year 2006 A. CST and CDJ Operations On January 1, 2006, CST entered into an agreement to lease the Harrisonville parcel from CDJ from January 1, 2006, to January 1, 2016. CST used this real estate to operate its used car busi…
62. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    income tax return. Although the Court can appreciate petitioners' frustration, we must nevertheless note that matters involving interest do not, as a general rule, fall within the scope of this Court's jurisdiction. Perkins v. Commissioner , 92 T.C. 749, 752 (1989); LTV Corp. v. Commissioner , 64 T.C. 589, 597 (1975); …
63. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011
    efore the loan was not a taxable distribution in 2003. On March 21, 2006, the Air Force removed petitioner from service and 'notified the TSP. The Air Force did not reinstate petitioner within 31 days from March 21, 2006. As a result, the TSP notified petitioner that the loan provisions required repayment of the outsta…
64. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004related by meaning
    …ent’s litigating position that the distribution occurred in 2000. See Garcia v. Commissioner , T.C. Memo. 1998-203 (reaching this conclusion regarding another question and answer contained in the same proposed regulation), affd. without published opinion 190 F.3d 538 (5th Cir. 1999). Additionally, the substantially lev…
65. T.C. Memo. 2016-55 — Brenda S. Jones v. Commissioner
    IRCCourt RulingsMar 28, 2016
    …Life insurance policy Year allocation accumulation value 2004 $88,237 $113,607 2005 111,763 204,135 2006 -0- 303,317 John Machacek was fully vested under the terms of the SBP in 2005 and 2006. In 2005 and 2006 he would have been entitled to a preretirement or postretirement death benefit of approximately $786,000.4 The…
66. T.C. Memo. 2007-206 — Alex B. Rhodes, Jr. v. Commissioner
    IRCCourt RulingsJul 30, 2007
    …d a penalty on petitioner of $2,000 under section 6673(a)(1) . See Rhodes v . Commissioner , T .C . Memo . 2003-133 ; affd . 152 Fed . Appx . 340 (5th Cir . 2005) . In the above-docketed case, the Court has warned - 7 - petitioner on six occasions of the possibility of imposing a penalty under section 6673(a)(1) if he …
67. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    …t is too late .for, the taxpayer to elect joint filing status . . Brattin v . Commissioner , r .C . Memo . 1992-625 (citing Thompson v . Commissioner , 78 T .C . 558, 561 (1982), an d Phillips v . Commissioner , 86 T .C . 433, 441 n . :7 : (1986), affd . as to this issue 851 F .2d 1492 (D .C : Cir . .1988))` . 16
68. T.C. Memo. 2020-5 — Ed Thielking, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 2020
    …inently in prior cases before this Court. See Val Lanes Recreation Ctr. Corp. v. Commissioner, T.C. Memo. 2018-92; Churchill, Ltd. Emp. Stock Ownership Plan & Tr. v. Commissioner, T.C. Memo. 2012-300; Hollen v. Commissioner, T.C. Memo. 2011-2, aff'd per curiam, 437 F. App'x. 525 (8th Cir. 2011). This case involves an S…
69. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    l T.C. Memo. 2011-105 UNITED STATES TAX COURT WEEKEND WARRIOR TRAILERS, INC. , ET AL . , i Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 6984-08, 6997-08, Filed May 19, 2011. 15166-08. Pietro E. Canestrelli and Stanley A. Harter, for petitioners. Heather K. McCluskey and Monica D. Gingras, for…
70. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …ne who financially benefits from the transaction." Tigers Eye Trading, L.L.C. v. Commissioner, T.C. Memo. 2009-121 (citing Hansen v. Commissioner, 471 F.3d 1021, 1031 (9th Cir. 2006) (''a taxpayer cannot negate the negligence penalty through reliance on a transaction's promoters or on other advisors who have a conflict…
71. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
72. T.C. Memo. 2013-45 — Alan R. & Toni A. Pinn v. Commissioner
    IRCCourt RulingsFeb 11, 2013
    …. See Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729 (1929); Sanders v. Commissioner, T.C. Memo. 2010-279, 2010 WL 5327897, at *2; McGowen v. Commissioner, T.C. Memo. 2009-285, 2009 WL 4797538, at *3-*5, aff'd, 438 Fed. Appx. 686 (10th Cir. 2011); Barr v. Commissioner, T.C. Memo. 2009-250, 2009 WL 3617587, at …
73. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
74. Treas. Reg. § 1.72(p)-1(b) — Loans treated as distributions.
    IRCRegulationsSep 17, 2024
    …n section 72(p)(2)(A). The amount of the new loan is $40,000, the outstanding balance on January 1, 2006, of the loan it replaces is $33,322, and the highest outstanding balance of loans from the plan during 2005 was $40,000. Accordingly, under section 72(p)(2)(A), the sum of the new loan and the outstanding balance on…
75. PLR 200728042 — Additional Income and Taxes Generated from the Backdating or Discounting of Exercised Stock Options
    IRCPrivate Letter RulingsJul 13, 2007
    …ided that the amendment and election applies only to amounts that would not otherwise be payable in 2006 and does not cause an amount to be paid in 2006 that would not otherwise be payable in such year. See Preamble to the Proposed Regulations under §409A, §XI.C. Because the amount payable under the stock option was no…
76. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    … Andrew I. Panken and Robert A. DeVellis , for petitioner. Catherine R. Chastanet , for respondent. MEMORANDUM OPINION LARO, Judge : The parties submitted this case to the Court without trial. See Rule 122. Petitioner petitioned the Court to redetermine respondent's determination of the following deficiencies in Federa…
77. TR 2011-03 — Technical Release 2011-03
    ERISADOL Technical ReleasesSep 13, 2011
    …media in the manner prescribed by the regulation. See 29 CFR 2520.104b-1(c)(2)(ii). On December 20, 2006, the Department issued Field Assistance Bulletin 2006-03 (FAB 2006-03) to provide general guidance regarding good faith compliance with the changes made to the pension benefit statement provisions of section 105 of …
78. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsAug 6, 1996related by meaning
    Technical Advice Memorandum 8210014 (TAM) and in a series of private letter rulings. Respondent points out that section 6110(j)(3) prohibits using or citing a written determination as a precedent, unless regulations - 26 - provide otherwise, which is not the case here. See Estate of Jalkut v. Commissioner , 96 T.C. 67…