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81. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012related by meaning
    evidence. In addition, we decline to apply the Cohan rule to approximate itemized deductions because petitioners failed to comply with our orders, and they have not built a sufficient evidentiary foundation from which we can apply the Cohan rule to approximate any itemized deductions to which they are entitled. We also…
82. T.C. Memo. 2017-201 — Joseph E. Bormet v. Commissioner
    IRCCourt RulingsOct 16, 2017related by meaning
    T.C. Memo. 2017-201 PA UNITED STATES TAX COURT JOSEPH E. BORMET, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6863-16. Filed October 16, 2017. Bradley S. McCann, for petitioner. Angela B. Reynolds and Briseyda Villalpando, for respondent. MEMORANDUM OPINION GOEKE, Judge: Respondent determined a…
83. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
84. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
85. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    o. 17204-09 Additions to tax and penalty Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)' Sec. 6662A 2004 $28,779 $1,179.23 to be determined $9,259.32 2005 83,908 2,131.20 to be determined . 21,855.65 2006 62,339 3,645.68 to be determined 13,879.43 1Respondent explains in the notice of deficiency that the additions to …
86. 124 T.C. No. 10 — John Michael Dunkin v. Commissioner
    IRCCourt RulingsMar 31, 2005
    …y share of a lump-sum distribution from a qualified pension plan. Powell v. Commissioner , 101 T.C. 489, 498 (1993). 3. Respondent’s Contentions Respondent contends: (a) Petitioner is taxable on the payments he made to his former spouse on account of her community property rights in his pension because, unlike the spou…
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. T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …t balance of $56,629; veterans’ benefits, Social Security benefits, and employer vacation pay of $5,489; and 2016 distributions from a Fidelity account of $7,722. Appeals Officer Duff then reduced the sum of those amounts ($223,996) by “allowed debits and checks” of $11,729. These allowed debits and checks included, am…
89. T.C. Summary Opinion 2005-51 — Lee E. Seidel v. Commissioner
    IRCCourt RulingsApr 19, 2005
    …WSC 401(k) plan are governed by section 402. Respondent relies on Powell v. Commissioner , 101 T.C. 489 (1993), in arguing that the funds distributed through the QDRO remained community property and should be taxed as an indirect distribution. Interpreting Darby v. Commissioner , supra , the Court in Powell v. Commissi…
90. 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’ …