IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
IRCCourt RulingsMar 31, 1961
…or $5,389.44 per year. During the year 1953 petitioner received 6 such monthly payments totaling $2,694.72, and reported $260.63 of this sum as taxable annuity income under the 3-percent-of-cost rule of section 22(b) (2), I.R.C. 1939, which action respondent has not contested.
During each of the years 1954, 1955, and 1…
IRCCourt RulingsDec 24, 1985
…izer Co., 455 U.S. at 24, Rowan Cos. v. United States, 452 U.S. at 253, and Bolton v. Commissioner, 694 F.2d 556, 560-563 (9th Cir. 1982). The inquiry for the Court remains whether the regulation is consistent with the statute’s plain language, origin, and purpose. National Muffler Dealers Association, Inc. v. United S…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsOct 10, 1979related by meaning
es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
IRCCourt RulingsDec 22, 1997related by meaning
T.C. Memo. 1997-556
UNITED STATES TAX COURT
A.C. GREEN ELECTRICAL CONTRACTORS, INC., Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8794-95. Filed December 22, 1997.
Bruce H. Guttman
, for petitioner.
Peter J. Gavagan
, for respondent.
MEMORANDUM OPINION
SWIFT, Judge
: Respondent determined defi…
IRCCourt RulingsDec 24, 1985related by meaning
terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange.
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
IRCCourt RulingsApr 25, 1972related by meaning
eon. 4, 064. 67
Tax increase due to premature distribution — 1966_ 395. 69
Increase in tax — sec. 72(m)(5) 110% timesff$395.69; to Schedule 1_ 435. 26 The parties have stipulated that the 1966 deduction claimed as an adjustment to gross income in the amount of $300 as payments made by a self-employed person to retireme…
89 FR 23090 — Amendment to Prohibited Transaction Class Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption) ERISAFinal Rules (FR)Apr 3, 2024
… fiscal year ending no later than December 31, 2027, substitute $118,912,000 for $85,000,000 and $1,694,000 for $1,000,000.