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81. 141 T.C. No. 19 — Andrew Wayne Roberts v. Commissioner
    IRCCourt RulingsDec 30, 2013related by meaning
    . - 26 - return or in a statement attached to the return and there is a reasonable basis for the taxpayer's treatment of the item. Sec. 6662(d)(2)(B). The Commissioner bears the initial burden of production with respect to the taxpayer's liability for the section 6662 penalty. Sec. 7491(c). At trial the Commissioner mu…
82. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014
    …discretion in rejecting an installment agreement where the taxpayer owned investments totaling $406,805 and noting that taxpayers do not generally qualify - 25 - [*25] for an installment agreement if balance due accounts can be fully or partially satisfied by liquidating assets). In McCarthy v. Commissioner, T.C. Memo.…
83. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    109 T.C. No. 9 UNITED STATES TAX COURT SQUARE D COMPANY AND SUBSIDIARIES, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 15047-94, 4991-95. Filed October 9, 1997. During December 1982, P established a voluntary employees' beneficiary association (VEBA) which qualified for exemption under sec. 5…
84. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    statutory provisions and the legislative histories of those provisions, we hold that petitioner's use of the distributions from his Keogh and IRA's to purchase stock which he then contributed to the Smith Barney IRA does not constitute a tax-free rollover contribution under section 402(c) or 408(d)(3), respectively. 3 …
85. 87 FR 80097 — Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled Qualified Investment Entities
    IRCProposed Rules (FR)Proposed Dec 29, 2022related by meaning
    (1)(iv) and 1.892-5(d)(5)(iii), which provide relief from being treated as engaged in certain deemed commercial activities. Back to Citation 4.   See, for example, proposed § 1.892-4(e)(1)(iv), which provides that gain derived from a disposition of a USRPI defined in section 897(c)(1)(A)(i) will not qualify for exempti…
86. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    the deduction would frustrate a sharply defined Federal or State policy. Wood v. United States , 863 F.2d 417 (5th Cir. 1989); Fuller v. Commissioner , 213 F.2d 102 (10th Cir. 1954), affg. 20 T.C. 308 (1953); Holmes Enterprises v. Commissioner , 69 T.C. 114 (1977). The test of nondeductibility is the severity and imme…