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81. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…
82. T.C. Memo. 2006-47 — Diep N. Hoang v. Commissioner
    IRCCourt RulingsMar 20, 2006
    … witness's testimony that is self-interested or otherwise questionable. See Archer v. Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg. a Memorandum Opinion of this Court; Weiss v. Commissioner, 221 F.2d 152, 156 (8th Cir. 1955), affg. T.C. Memo. 1954-51; Schroeder v. Commissioner, T.C. Memo. 1986-467. There is no…
83. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
    IRCCourt RulingsSep 21, 1962related by meaning
    2,1953, and 1954 under the provisions of section 272(e) of the Internal Revenue Code of 1939 and section 6214(a) of the Internal Revenue Code of 1954. A number of issues raised by the pleadings have been settled by the parties, and one issue was conceded by respondent on brief, leaving for our decision the following: (…
84. T.C. Memo. 1998-388 — Robert B. Keenan v. Commissioner
    IRCCourt RulingsNov 2, 1998
    …as taxable income to him during that year.) On December 31, 1989, petitioner's IRA's had values of $227,906.56 in account No. 435 and $177,642.40 in account No. 860 (totaling $405 ,548.96). Petitioner concedes that he caused distributions of $408,623 6 from account Nos. 435 and 860 in 1990. At some point, petitioner es…
85. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
86. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
87. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    …31 - promulgated in the exercise of that authority." United States v. Mead Corp., 533 U.S. 218, 226-227 (2001); see Barnhart v. Walton, 535 U.S. 212, 221-222 (2002). Lastly, as stated, in 2006 the Secretary promulgated final regulations reflecting the position set forth in Revenue Ruling. 2001-6. See sec. 1.162(k)(1), …
88. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
89. T.C. Summary Opinion 2004-146 — Jack A. & Theresa Y. Smith v. Commissioner
    IRCCourt RulingsOct 21, 2004related by meaning
    T.C. Summary Opinion 2004-146 UNITED STATES TAX COURT JACK A. AND THERESA Y. SMITH, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11507-02S. Filed October 21, 2004. Randy P. Zinna , for petitioners. Brenda Fitzgerald , for respondent. PAJAK, Special Trial Judge : This case was heard pursuant t…
90. 136 T.C. No. 6 — Michael P. Schwab & Kathryn J. Kleinman v. Commissioner
    IRCCourt RulingsFeb 7, 2011
    …the Code as far back as 1921 in section 219(f), Revenue Act of 1921, ch. 136, sec. 219(f), 42 Stat. 227, 247,.which became section 165 in 1928, Revenue Act o.f 1928, ch. 852, sec. 165, 45 Stat. 791, 839." Schwab and Kleinman point out that the .committee reports for both the 1928 and 1932 Acts don't address taxing the …
91. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment. SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
92. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    settlement agreement is not a qualified domestic order, and Mr. Ahmad is not an alternate payee, the exception in section 72(t)(2)(C) is inapplicable. In light of the foregoing, the Court holds that petitioners are liable for the 10-percent additional tax imposed under section 72(t). Reviewed and adopted as the report …