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81. T.C. Memo. 2000-171 — Van Roekel Farms, Inc. v. Commissioner
    IRCCourt RulingsMay 24, 2000
    …ness Type of salaries 1 income business Year (Line 7, Form 1040) (Schedule C) (Schedule C) 1994 $12,776 $15,000 Farm management 1995 12,967 18,000 Farming 1996 13,356 15,000 Farm management 1 The wages are attributable solely to Darlene, a secretary at the Orange City Municipal Hospital in Iowa. Respondent disqualified…
82. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …923,654 39,780,939 599,321 6/30/83 35,347,336 513,695 35,861,031 (1,564,606) 6/30/84 65,700,275 702,776 66,403,051 2,409,636 6/30/85 72,255,521 764,275 73,019,796 (50,720) 6/30/86 81,916,703 829,481 82,746,184 1,752,870 6/30/87 94,305,548 962,317 95,267,865 4,098,466 6/30/88 112,993,217 1,725,585 114,718,802 6,871,287 …
83. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
84. T.C. Memo. 1996-446 — Kay A. Clawson v. Commissioner
    IRCCourt RulingsSep 30, 1996related by meaning
    Pub. L. 102-318, sec. 521, 106 Stat. 291, 308, for years after Dec 31, 1992. For the year 1990, which is here in issue, sec. 402(a)(9) was in effect. Within the broad rubric of section 61(a), which defines gross income as all income from whatever source derived, the law is clear that a distribution from a qualified re…
85. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    -2503 at 95-2504, 95-1 USTC par. 50,280 (D. Md. 1995); see also Conway v. United States , supra ; cf. Wheeler v. Commissioner , T.C. Memo. 1993-561. 6 We observe that the definition of "qualified total distribution" set forth in section 402(a)(5)(E)(i)(II) incorporates the definition of "lump sum distribution" set fort…
86. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    t type rights, or through a settlement agreement entered into in lieu of such prosecution." Sec. 1.104-1(c), Income Tax Regs. Thus, the exclusion must derive from some sort of tort claim against the payor. Rickel v. Commissioner , 900 F.2d 655, 658 (3d Cir. 1990), affg. in part and revg. in part on other grounds 92 T.C…
87. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
88. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    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…
89. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015
    …er of the payment to each of the Benenson Roth IRAs. Both Benenson Roth IRAs received $42,831, $221,776, $206,394, and $267,513 from JC Holding on January 18, April 23, July 25, and December 22, 2008, respectively. Both Benenson Roth IRAs received $17,765 from JC Holding on January 27, 2009. 5JC Export reported the $12…
90. 44 T.C. 335 — F. & D. Rentals, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1965
    …unemployment compensa-tion_ 4, 316. 86 Indiana gross income. 29. 10 Local property- 18, 896. 04 81, 776. 43 108, 017. 79 Provision for vacation and holiday pay_ 27, 616. 51 Provision for contribution to pension fund. 17, 500. 00 Total current liabilities_ $248, 435. 97 Capital Common stock — $10 par value; authorized 1…
91. 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 …
92. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
    IRCCourt RulingsNov 4, 1976related by meaning
    loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…