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81. 125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner
    IRCCourt RulingsNov 17, 2005
    …mmissioner, 624 F.2d 884, 885 (9th Cir. 1980); Trust Servs. of Am., Inc. v. United States, 885 F.2d 561, 569 (9th Cir. 1989)), affg. 67 T.C. 234 (1977). The Court of Appeals compared the situation with stock subject to resale restrictions that prevented it from being sold freely in a public market. Shackleford v. Unite…
82. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    ximum of 46% of the combined income to the FSC (by adjusting the sale 1 transfer price). If the profit margin was between 3.98% and 7.96%, the maximum amount of taxable income assignable varied inversely from 46% to 23%, respectively. If the profit margin exceeded 7.96%, they could assign a maximum of 23% of the combin…
83. T.C. Memo. 2010-262 — Hal Hollingsworth v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …t the receipt failed to state whether the donee provided goodst or services) Gaffd. 188 Fed.- Appx. 561 -(9th Cir. 2006) . "(...continued) authenticity. The issue of admissibility is moot because petitioner is not entitled to sa deduction for charitable contributions žegardless of whether the documents marked as Exhibi…
84. U.S. Tax Court — Michael K. Billups v. Commissioner
    IRCCourt RulingsJun 1, 2009related by meaning
    account of the employee's disability ; (4) as part of a serie s e for life ; (5) to a employee after separation from service after attainment of ag A substantially equal periodic payments m 55 ; (6) as dividends paid with, respect to corporate stoc k described in section 404(k) ; (7) to an employee for medica l or (8)…
85. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015
    …rather than to the particular form the parties employed." Frank Lyon Co. v. United States, 435 U.S. 561, 573 (1978). The substance over form doctrine applies when the transaction on its face lies outside the plain intent of the statute and respecting the transaction would be to exalt artifice above reality and to depri…
86. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    nt and other official explanations of such treaties; court cases; congressional intent as reflected in committee reports, joint explanatory statements of managers included in conference committee reports, and floor statements made prior to enactment by one of a lhill's managers; General Explanations of tax legislation …
87. T.C. Summary Opinion 2002-138 — Robert L. & Sara J. Helm v. Commissioner
    IRCCourt RulingsOct 18, 2002
    …ing the years in issue: 1998 1999 Petitioner Robert L. Helm $2,277 $9,228 Petitioner Sara J. Helm 6,561 6,654 Total 8,838 15,882 C. Petitioners’ Forms 1040
88. T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (…
    IRCTreasury DecisionsMar 7, 2005related by meaning
    INCOME TAX Rev. Rul. 2005-13 Rev. Rul. 2005-13 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2005. T.D. 9175 T.D. 9175 Temporary and proposed regula…