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81. T.C. Memo. 2001-114 — John & Christina Wade v. Commissioner
    IRCCourt RulingsMay 14, 2001
    …eumeister v. Commissioner , T.C. Memo. 2000-41, affd. without published opinion 2001-1 USTC par. 50,235, 87 AFTR 2d 2001-819 (6th Cir. 2001). The formula set forth in section 219(g)(2) and (3) results in a total disallowance of the IRA deduction where the total modified AGI reported on a joint return exceeds $50,000. S…
82. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
83. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006
    …ust apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. Commissioner , 464 U.S. 386, 398 (1984) (“Courts are not authorized to rewrite a statute because they might deem its effe…
84. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
85. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
86. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997
    …ning of the statutory language is conclusive. United States v. Ron Pair Enterprises Inc. , 489 U.S. 235, 242 (1989). Where a statute is silent or ambiguous, we may look to legislative history in an effort to ascertain congressional intent. Burlington N. R.R. v. Oklahoma Tax Commn. , 481 U.S. 454, 461 (1987); Griswold v…
87. 71 T.C. 1011 — Orthopedics International, Ltd., P.S. v. Commissioner
    IRCCourt RulingsMar 19, 1979related by meaning
    section 404(a)(7) and section 1.404(a)-13, Income Tax Regs., is reasonable and wé refuse to hold it invalid. Decision will be entered under Rule 155. Petitioner has also agreed to an adjustment to its taxable income made by respondent for forfeitures not properly offset by petitioner against its allowable pension plan…
88. 29 C.F.R. § 4281.14-4281.15 — [Reserved]
    PBGCRegulationsJul 1, 2019related by meaning
    [Reserved]
89. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…