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81. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008related by meaning
    ified retirement plan during 2002, before he had attained age 59-1/2 . Thus, even if the additional tax under section 72(t) is a "penalty, addition to tax, or additional amount" within the meaning of section 7491(c), a point we do not decide, there is ample evidence in the record to satisfy any burden of production imp…
82. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
83. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
84. T.C. Memo. 2010-262 — Hal Hollingsworth v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …ue 43-T.C. 168 (1964) and T.C. Memo. 1964-299), affd. 904 F.2d 1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991) Negl'igence can also include any failure by the tåxpayer to-keep adequate récords and to substantiate items properly. Sec. 1.666223 (b) (1-) , Income Tax Regs. A substantial4understatèment of income tax is an …
85. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015
    … claimed a deduction of $2,060,684 for DISC commissions. On its 2008 tax return Summa reported $368,868,519 of gross sales, $27,710,847 of which was derived from the sale of qualified export property under section 993(c). It claimed a deduction of $2,150,896 for DISC commissions. Protective Refund Claims On July 9, 201…
86. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    w that there is a genuine dispute for trial that he had reasonable cause for not paying the unpaid tax on the 2013 return made for him by RA Landadio. C. Summary Judgment Rule 121(b) provides that, in the absence of a genuine dispute as to any material fact, and if a decision may be rendered as a matter of law, we must…
87. 137 T.C. No. 2 — Robert K. & Joan L. Paschall v. Commissioner
    IRCCourt RulingsJul 5, 2011
    …eytag v. Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d.1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991); LaPlante v. Commissioner, T.C. Memo. 2009-226. "The advice must be from competent and independent parties, not from promoters of the investment" or advisers who have a conflict of inte est. Swanson v. Commiss…
88. Treas. Reg. § 54.4975-14(c) — Election to pay an excise tax for certain pre-1975 prohibited transactions.
    IRCRegulationsDec 30, 2016related by meaning
    (c) (c) Method of election. A person shall make the election referred to in this section by filing the form issued for such purpose by the Internal Revenue Service, including therein the information required by such form and the instructions issued with respect thereto, and by paying the tax which the taxpayer indicate…
89. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    motion for costs was filed out of time and should be "dismissed" for that reason. We reject respondent's contention and do not consider it further. 12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is generally applicable to proceedings commenced after …
90. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    es applicable t o annuity distributions from CRATs. Thus, to the extent sections 72 and 664 called for different treatment, section 664 would control. Second, section 7 2 do es not call for different treatment. Section 72(b)(1) allows an exclusion from income only to the extent the taxpayer has an “investment in the co…
91. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …25 investors in MIT 83 paid their share of the required cash in full in 1983, in the amount of $118,868, plus $13,902 in interest. BBPA issued a note receivable to MIT 83 representing payment in respect of the cash required of the other eight investors in MIT 83, who issued short-term promissory notes to MIT 83. The - …
92. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…