IRCCourt RulingsOct 3, 1995related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTE…
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961related by meaning
e distribution.
Although section 816 of the 1954 Code rather than section 115 of the 1939 Code is applicable here, the relevant language is identical. The dividend issue was raised expressly by respondent for the first time at the trial by the statement that “the amounts involved in this case are * * * a preferential o…
IRCCourt RulingsMar 31, 1997related by meaning
ons of the Internal Revenue Code in effect for the years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
- 3 - After concessions, the following 2 issues remain for us to
resolve in the present proceeding: (1) Whether petitioner, in
its taxable year ending January 30, 1988 (TYE 88…
IRCCourt RulingsFeb 10, 1997related by meaning
e within the parameters
spelled out in section 404(a)(6), may be deducted in the prior
year, but only
if
they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's
Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
IRCCourt RulingsJul 25, 2023
…We thus follow its precedent. See Golsen v. Commissioner, 54 T.C. 742, 757 (1970), aff’d , 445 F.2d 985 (10th Cir. 1971).
During 2018 petitioner was employed by the N ew York City
Transit Authority. For that year it paid him wages o f $80,764, reporting
that amount to him on Form W – 2, Wage and T ax Statem ent . He do…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
s less than the dollar amount accrued, the foreign tax credit for the year in question should be correspondingly adjusted. We hold for the respondent. Initially, we note that the Code encompasses a system of taxation in respect of income of United States persons and of income of non-United States persons from sources w…
IRCCourt RulingsJun 15, 2009
…binette in
this case . See Golsen v . Commissioner , .54 T .C . 742 ., 757 (1970),
affd . 445 F .2d 985 (10th Cir . 1971) ; see also Lardas v .
Commissioner , 99 T .C . 490, 494-495 (1992) .
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
IRCCourt RulingsSep 3, 1998
…331,
450; S. Rept. 104-281 at 80 (1996); H. Conf. Rept. 104-737 at
245-246 (1996), 1996-3 C.B. 741, 985-986.
7
Since the years involving the elective deferrals are
fiscal years ending June 30, 1986, and June 30, 1987, only a
portion of the employee contributions would have been included.
Sec. 415(c)(2)(B); see supra
no…
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…