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81. 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 …
82. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …party. United States v. Diebold, Inc., 369 U.S. 654, 655 (1962); Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985). The parties contend that there are no genuine issues as to any material fact and that a decision may be rendered as a matter of law. For the reasons discussed below, we do not agree. Accordingly, we will…
83. T.C. Memo. 2019-145 — Jane M. Lassek, Petitioner and Michael E. Smith, Intervenor v. Commissioner
    IRCCourt RulingsOct 28, 2019related by meaning
    s not apply in the case of an underpayment of tax reported on a joint return. Sec. 6015(b)(1)(B), (c)(1). When a liability arises from an underpayment of tax reported as due on a joint return, relief is available only under section 6015(f). See sec. 6015(b)(1)(B), (c)(1), (f)(1); Hopkins v. Commissioner, 121 7Because p…
84. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005
    …moving party. Craig v. Commissioner , 119 T.C. 252, 260 (2002); Dahlstrom v. Commissioner , 85 T.C. 812, 821 (1985); Jacklin v. Commissioner , 79 T.C. 340, 344 (1982). The party opposing summary judgment must set forth specific facts which show that a question of genuine material fact exists and may not rely merely on …
85. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
86. T.C. Memo. 1996-292 — Galen J. Smith v. Commissioner
    IRCCourt RulingsJun 24, 1996
    …e to the non-moving party. Kroh v. Commissioner , supra at 390; Dahlstrom v. Commissioner , 85 T.C. 812, 821 (1985). 2. Separate notices of deficiency Respondent determined that petitioner owes an income tax deficiency arising from the distributions from his former spouse's qualified retirement and pension plans. In th…
87. T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …l greater than a 22 The orphan’s courts are Maryland’s probate courts. Radcliff v. Vance , 757 A.2d 812, 816 ( Md. 2000). 23 For example, the Estate alleges that Appeals Officer Duff erroneously included in the reasonable collection potential computation veterans’ benefits that were ultimately returned and a $20,000 tu…
88. 143 T.C. No. 21 — Key Lime Investments, Inc. v. Commissioner
    IRCCourt RulingsNov 26, 2014
    …eated in a manner that is most favorable to the nonmoving party. Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985). While the burden falls on the moving - 7 - party, the nonmoving party "may not rest upon the mere allegations or denials of such party's pleading, but such party's response * * * must set forth specific …
89. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    . 2d 575 (C.A. 8, 1973); Azad v. United States, 388 F. 2d 74 (C.A. 8, 1968); Alsco Storm Windows, Inc. v. United States, 311 F. 2d 341 (C.A. 9, 1962). The test usually considered fundamental in establishing whether certain individuals constitute common law employees of another is whether the person for whom the work is…