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81. T.C. Memo. 2010-200 — Cheryl Elizabeth & Don Edward Hill v. Commissioner
    IRCCourt RulingsSep 13, 2010
    … home . buyers .' On-the rn, after consideration of . .prior withholdings . reported tax due of $15,384 . onsideration of the 2004 amended-return respondent : issued a sup lemental notice of determination-to,petitioners denying in fill their : claims on the amended return . Durin g librarian a t school and o estate pro…
82. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    rst articulated. 3 As a consequence, we set forth that analysis in order to bring into focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid" when the letter of credit was purchased on March 13, 1992. Statutory Framework The parties have stipula…
83. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010
    …e of stock to an employee represented taxable income to the employee) ; Lowndes v . United States , 384 F .2d 635 ( 4th Cir . 1967 ) ; Haag v . Commissioner , 40 T .C . 488 ( 1963 ), affd . .334 F .2d 351 ( 8th Cir . 1964 ) ; Waldheim v . Commissioner , 25 T .C . 839, 850-851 (1956),
84. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    r personal injuries or sickness to the extent such amounts are (A) attributable to - 11 - 7 Former sec. 105(d) provided a limited exclusion from gross income for amounts received in lieu of wages prior to attaining age 65 by completely disabled persons retired on disability. Sec. 105(d) was repealed by sec. 122(b) of t…
85. T.C. Memo. 2009-187 — Eugene & Glenda Dollander v. Commissioner
    IRCCourt RulingsAug 19, 2009
    …for 2005 a deficiency in petitioners' income tax of $16,918 and an accuracy-relate d ,penalty of $3,384 . After concessions by petitioners, the issues before the Court are : (1) Whether petitioners are liable for the 10-percent additional tax under section 72(t) with respect to an early distribution from a . qualified …
86. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    r) during the taxable year, and (5) made to carry on a trade or business. See Commissioner v. Lincoln Sav. & Loan Ass'n, 403 U.S. 345, 352-353 (1971); Lychuk v. Commissioner, 116 T.C. 374, 386 (2001). C. Our Country and Environmental Our Country and Environmental must clear another hurdle in addition to section 162(a).…
87. T.C. Summary Opinion 2004-100 — Kurt Steven & Juanita Fay Urban v. Commissioner
    IRCCourt RulingsJul 27, 2004
    …uthoritative sources of law in the tax field. Casa De La Jolla Park, Inc. v. Commissioner , 94 T.C. 384, 396 (1990). Taxpayers must look to authoritative sources of Federal tax law such as the statutes, regulations, or judicial decisions. Green v. Commissioner , 59 T.C. 456, 458 (1972).
88. I.R.C. § 405 — [§405. Repealed. Pub. L. 98–369, div. A, title IV, §491(a), July 18, 1984, 98 Stat. 848]
    IRCCode / StatuteJan 4, 1995related by meaning
    [§405. Repealed. Pub. L. 98–369, div. A, title IV, §491(a), July 18, 1984, 98 Stat. 848]
89. T.C. Memo. 2004-40 — Anthony J. & Denise D. Sadberry v. Commissioner
    IRCCourt RulingsFeb 18, 2004
    … instructions of the Internal Revenue Service. Casa de la Jolla Park, Inc. v. Commissioner, 94 T.C. 384, 396 (1990); Wenger v. Commissioner, T.C. Memo. 2000-156. Moreover, any error in the instructions was one of opinion or law, not fact. Here, petitioners knew all the facts and were not ignorant of them. They knew the…
90. T.C. Memo. 1998-399 — Ronny H. & Charlotte A. Schmalzer v. Commissioner
    IRCCourt RulingsNov 10, 1998related by meaning
    tstanding rollover involved in this case. Accordingly, the amount of excludable basis in the instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is $1,950 and the denominator of which is $1,374.53 plus $6,100, resulting in an amount excludable of $1,591.40.…
91. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    ensation may not avoid taxation by anticipatory arrangements regardless of their technical elegance. United States v. Basye, 410 U.S. 441, 450 (1973). In Armantrout v. Commissioner, 570 F.2d 210 (7th Cir. 1978), affg. per curiam 67 T.C. 996 (1977), an employer paid sums to a trustee who, in turn, paid school expenses f…
92. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    ment provides A with notice of the specific amount of the liability and the basis for that liability as described in this paragraph (a)(7). Example 2. Taxpayer B is a partner in partnership P, a TEFRA partnership for taxable year 2005. B claims a distributive share of partnership income on B's Federal income tax return…
93. T.C. Summary Opinion 2013-42 — Aster Tirfe v. Commissioner
    IRCCourt RulingsJun 3, 2013related by meaning
    itional rental expenses incurred as a result of the unlawful detainer action. . We agree with respondent. Given the manner in which the jury award was allocated, the actual damages portion obviously relates to financial or economic losses petitioner suffered as a result of the retaliatory eviction. Damages on account o…