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81. T.C. Memo. 1999-161 — Roblene, Inc. v. Commissioner
    IRCCourt RulingsMay 13, 1999
    …32,922 -- 1988 0 53,718 Real Estate Sales 1989 31,426.65 57,271.12 Real Estate Sales 1990 40,040 60,543 Realtor For 1989, we note that no W-2 is included in the record to determine the source of the $31,426.65 of salaries and wages. Since petitioner paid $0 in compensation to officers and $0 in salaries and wages for 1…
82. 105 T.C. 29; 105 T.C. No. 3 — Rodoni v. Commissioner
    IRCCourt RulingsJul 24, 1995related by meaning
    eceived the distribution is not merely procedural with a view to the orderly conduct of business, but rather it relates to the essence of the statute. Second, petitioners argue that they substantially complied with the QDRO provisions of section 414(p) and thus qualify for tax-free rollover treatment under section 402(…
83. T.C. Memo. 1998-145 — Estate of Hilda Ashman, Deceased; Phillip Ashman, Personal Representative v. Commissioner
    IRCCourt RulingsApr 22, 1998
    …on or report, and the change is detrimental to the Commissioner. LeFever v. Commissioner , supra at 543; see also Herrington v. Commissioner , supra at 758; Shook v. United States , 713 F.2d 662, 667 (11th Cir. 1983); Beltzer v. United States , 495 F.2d 211, 212 (8th Cir. 1974); Cluck v. Commissioner , 105 T.C. 324, 33…
84. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent. Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
85. T.C. Summary Opinion 2007-129 — Jeffrey Lee Golian v. Commissioner
    IRCCourt RulingsJul 26, 2007related by meaning
    sioner , T .C . Memo . 2001-34 . We recognize that petitioner received his IRA distribution at a time when he was both a single parent and temporarily unemployed and that he used the distribution for a laudable purpose . Unfortunately for petitioner, we are bound by the lis t of statutory exceptions set forth in sectio…
86. 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 …
87. 91 T.C. 769; 91 T.C. No. 49 — Estate of Christmas v. Commissioner
    IRCCourt RulingsOct 6, 1988related by meaning
    n of the transitional rule and denial of the unlimited marital deduction is, therefore, consistent with, and does not frustrate, congressional intent. Because we have concluded that the marital deduction provision in decedent’s will is a marital deduction formula to which section 403(e)(3) of ERTA applies, the marital …
88. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    fic terms and requirements that, in a reasonable manner, interpret and carry out the general concepts embodied in the statute and legislative history. Thus, we hold that the temporary regulation is valid. Applicability of Temporary Regulation to Petitioner's Yearend Bonus Payments In the alternative, petitioner argues …
89. T.C. Summary Opinion 2020-14 — Dale W. Laue & Alicia Laue v. Commissioner
    IRCCourt RulingsApr 20, 2020
    …ve evidence of the statutory purpose. See United States v. Am. Trucking Ass'ns, Inc., 310 U.S. 534, 543 (1940); Bronstein v. Commissioner, 138 T.C. 382, 386 (2012). Statutory text is ambiguous where "the ordinary and common meaning of the statutory language supports more than one interpretation". Carlson v. Commissione…
90. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    ny asserted abnormality under section 433 (b) (9) of the 1939 Code, was $770,547.83, $754,407.22, $670,214.40, and $497,443.65, respectively. OPINION. The first issue is whether the deduction claimed by the petitioner for officers’ compensation in the base period year ended January 31, 1947, entitles petitioner to cert…
91. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020
    …274(d). Moreover, the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930), to estimate expenses covered by section 274(d). Sanford v. Commissioner, 50 T.C. at 827; sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). Taxpayers lacking a contem…