115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000related by meaning
115 T.C. No. 33
UNITED STATES TAX COURT
SHERWIN-WILLIAMS COMPANY EMPLOYEE HEALTH PLAN TRUST, KEY TRUST
COMPANY OF OHIO, TRUSTEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21333-97. Filed November 9, 2000.
Trust (T), a tax-exempt voluntary employees’
beneficiary association described in sec.…
IRCCourt RulingsFeb 9, 1998
…fd. without published
opinion 559 F.2d 1207 (3d Cir. 1977); Kelly v. Commissioner
, T.C.
Memo. 1987-352, affd. without published opinion 858 F.2d 743
(11th Cir. 1988). Petitioner's failure to file a valid tax
return for 1989 was not due to reasonable cause. Rather,
petitioner enclosed a letter with the return that stat…
IRCCourt RulingsJun 2, 2005related by meaning
from her 32-year marriage other
than a 50-percent interest in Mr. Kelley’s retirement plan.
Unfortunately for petitioner, this fact does not serve to overcome the clear mandate of section 402 defining the taxability
of distributions from an employees’ trust.
Finally, we recognize that on several occasions in the past,…
IRCCourt RulingsMar 14, 2019
…pute that liability here, he failed to carry his burden of
proving that he did not receive the $147,352 of wage and retirement income that
remains at issue.4
3The State of California supplied a copy of a canceled check made out to
petitioner for $45,251, bearing his signature on the endorsement line. He testified
that …
IRCCourt RulingsOct 20, 2003related by meaning
result apparently so at
odds with accepted tax policy.” Darby v. Commissioner
, supra
at
68.
We find that petitioner did not have a basis in the 1999 distribution from his section 401(k) plan, and that petitioner
properly included the full distribution in his 1999 gross income.
Accordingly, we hold that petitioner is l…
IRCCourt RulingsApr 10, 1963related by meaning
nt benefits was founded upon a law of Congress, the Supreme Court did not decide whether it might also be founded upon a contract with the Government. In Cecil W. Taylor, 2 T.C. 267 (1943), affirmed sub nom. Commissioner v. Miller, 144 F. 2d 287 (C.A. 4, 1944), we held that amounts withheld as retirement deductions fro…
IRCCourt RulingsSep 23, 2014
… when it interpreted a statute in a way that
conflicts with the statutory language), rev'g 104 T.C. 352 (1995); Limited, Inc. v.
- 21 -
Commissioner, 286 F.3d 324, 336 (6th Cir. 2002) ("[I]t is not the Tax Court's role
to inject its own policy determinations into the plain language of statutes."), rev'g
113 T.C. 169 (1…
IRCCourt RulingsMar 13, 2008
…4 ; Gallagher v . Commissioner , T .C .
Memo . 2001-34 ; Deal v . Commissioner , T .C . Memo . 1999-352 ; Duffy
v . Commissioner , T .C . Memo . 1996-556 ; Pulliam v . Commissioner ,
T .C . Memo . 1996-354 .
Petitioner also argues that his ignorance of the 10-percent
additional tax should except him from liability to p…
IRCCourt RulingsAug 13, 1999related by meaning
penses which are ordinary
and necessary and recurring in nature. Respondent relies on Rev.
Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring
expenses paid by an employer are not deductible under this
regulation. We disagree.
Our analysis starts at s…