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81. U.S. Tax Court — Jeremiah Francis O'Neill v. Commissioner
    IRCCourt RulingsAug 25, 2009
    …Commissioner v . Glenshaw Glass Co . , 348 U .S . 426, 429 (1955) (quoting Helvering v . Clifford , 309 U .S . 331, 334 (1940)) . Section 61 specifically includes annuities and pensions as items of gross income . Sec . 61 (a) (9) (11) . Statutory exclusions from income are matters of legislative
82. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
83. Rev. Rul. 2003-124 — Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contribu…
    IRCRevenue RulingsDec 8, 2003related by meaning
    INCOME TAX Rev. Rul. 2003-122 Rev. Rul. 2003-122 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2003. T.D. 9095 T.D. 9095 REG-136890-02 Final, temporar…
84. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …ct in determining that deficiency. See id. at 1000 (citing Graham v. Commissioner, 82 T.C. 299, 308-309 (1984) (and cases cited thereat)). Our review of respondent's exercise of discretion does not examine the method or procedure by which - 25 - respondent made his administrative determination of a deficiency. Rather, …
85. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …ed the income tax. Commissioner v. Kowalski, 434 U.S. 77, 82 (1977) (quoting Helvering v. Clifford, 309 U.S. 331, 334 (1940)). The Court explained that Congress intended "'to tax all gains except those specifically exempted.'" Id. at 82-83 (quoting Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 429-430 (1955)). Ther…
86. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    tomatic retroactive disqualification for operational errors is a “Draconian approach” that is not sanctioned by either the statute or the regulations. Respondent argues, however, that section 415 places restrictions on employers’ deductions for contributions to employee plans because deferred compensation plans are sub…
87. T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner
    IRCCourt RulingsApr 27, 1998
    … Court to redetermine respondent's determination of deficiencies in the amounts of $26,383 and $277,309 in its 1988 and 1989 Federal income tax, respectively, and additions thereto under section 6651(a) in the respective amounts of $6,596 and $69,327. - 2 - Following the estate's concession as to the 1988 and 1989 addi…
88. 30 T.C. 346 — Ryan Constr. Corp. v. Commissioner
    IRCCourt RulingsMay 23, 1958related by meaning
    ice of deficiency to each petitioner, determined that the payments to Carrie should not be eliminated through application of section 438 (b) (10) (C). In Arrow-Hart & Hegeman Electric Co., 7 T. C. 1350, this Court held that gratuity payments made by a corporation to widows of its deceased employees constituted a class …