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81. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    …olders as income that was left untaxed at the corporate level. Sees. 991, 995(a) and (b)(1); sec. 1.994-1(a)(2), Income Tax Regs.; see Summa II, 848 F.3d at 782; Addison Int'l, Inc. v. Commissioner, 887 F.2d 660, 666 (6th Cir. 1989), 90 T.C. 1207 (1988); Hellweg v. Commissioner, T.C. Memo. 2011-58, 2011 WL 821090, at *…
82. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010
    …ent was $166,798 and the surrender charge was $20,803 .7 .1, yielding a net surrender value of $145,994 .38 . As of March 16, 2006, the account value was $255,089 .19 . As of December 16 ., 2006, the surrender charge was $19,647 .95 . Between March 8 and 16, Benistar Plan and Mogelefsky executed a transfer of ownership…
83. Treas. Reg. § 54.9816-6A(b) — Use of claim adjustment reason codes and remittance advice remark codes.
    IRCRegulationsAug 3, 2026related by meaning
    (b) (b) Severability (b)(1) (1) Any provision of this section held to be invalid or unenforceable by its terms, or as applied to any person or circumstance, will be construed so as to continue to give maximum effect to the provision permitted by law, unless such holding is one of utter invalidity or unenforceability, i…
84. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    espondent’s First Amended Response to Petitioner’s Motion for Partial Summary Judgment filed on November 28, 2023, the Commissioner argues as follows: Petitioner states that “Congress has made a legislative judgment that Respondent ought not to be able to pursue deficiencies under section 4973 by issuing a Notice of De…
85. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981
    …in Vogel Fertilizer Co. v. United States, 225 Ct. Cl._, 634 F.2d 497 (1980), cert. granted 450 U.S. 994 (1981). The issue in those cases is whether for purposes of the 80-percent ownership test a shareholder’s stock should only be taken into account if he owns stock in each member of the controlled group. Present sec. …
86. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    s less than the dollar amount accrued, the foreign tax credit for the year in question should be correspondingly adjusted. We hold for the respondent. Initially, we note that the Code encompasses a system of taxation in respect of income of United States persons and of income of non-United States persons from sources w…
87. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971
    …ine Smith sold their American Gas stock to Union Oil. The sale price finally agreed upon was $1,786,994.75, of which 459,812.13 was paid in 1961 and the balance was to be paid in annual installments over a 5-year period. On their 1961 joint Federal income tax return, the Smiths properly elected to report their gain fro…