T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner IRCCourt RulingsJun 17, 1998
…liminary
valuation" of the four parcels. We hold that decedent's land had
a fair market value of $1,865,500, as of August 29, 1989.
- 22 -
With respect to the private annuity, petitioner contends
that the annuity, as of August 29, 1989, had a value of
$1,865,500, and that the accountant hired to determine the annual
pa…
IRCCourt RulingsSep 25, 1996★ strong match
… of Machise. MIT 82 also accrued a pension contribution expense of $43,907.
13
The total was $2,504,865.
As with MIT 80, the employee leasing agreement required
Machise to pay to MIT 82 a "compensation fee" of 115 percent of
the payroll costs paid by MIT 82, plus 115 percent of the amount
MIT 82 paid to Intercoastal fo…
IRCCourt RulingsApr 2, 2020
…he sum of
all three amounts due was shown as $10,557. For 2004, line 19.a showed the tax
due as $46,865; line 19.b (for penalties) was blank; and line 19.c showed the
interest due "computed to 05/29/2011" as zero (specifically "0.00"). The sum of
all three amounts due was shown as $46,865. Below these amounts was the n…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsJul 31, 2000★ strong match
…for the
second year was $607.89, and, at the end of that year, the
conversion credit balance was $4,865.74 ($2,373.60 + $2,890.50 -
$607.89 + $209.53); the $209.53 is the interest of 4.5 percent
earned on the conversion credit balance (($4,865.74 - $209.53) x
4.5% = $209.53)). Of the conversion credit balance, $2,311.2…
IRCCourt RulingsMar 5, 2018
. Rev. 859, 865 (1982)).
- 100 -
But rich people buying cows they don't otherwise need in order to get the cow
subsidies isn't the same thing. See R¹³ The economic substance doctrine doesn't help the Commissioner here
either. If that doctrine is one of statutory construction, Congress specifically
turned it off for FSC…
U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner IRCCourt RulingsDec 13, 2018
… or
Profit-Sharing Plans, IRAs, Insurance Contracts, etc., for 2014, reflecting
distributions of $7,865 and $17,757, respectively, as early distributions with "no
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCCourt RulingsSep 18, 2014
…, over Mrs. Laremore's, is
$77,730.48. The agreement is that she will get half of that sum for
$38, 865.24. She will get that $38,865.24 via a QDRO being placed
on Mr. Laremore's traditional IRA so that that amount will be
transferred to her and the end result is that the parties will have
equally shared these retireme…
IRCCourt RulingsSep 25, 2019related by meaning
appreciate the difficulties that incarceration imposed on petitioner in
obtaining information that might show that he had deductible expenditures for 2013 that exceed the $6,100 standard deduction accorded him by respondent,
petitioner has not--either in his defense to the motion or in his justification for his
two co…
89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit IRCFinal Rules (FR)Dec 11, 2024
…hority:
26 U.S.C. 7805 * * *
* * * * *
Section 1.861-8T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f).
Section 1.861-9 also issued under 26 U.S.C. 861, 863(a), 864(e), 864(e)(7), 865(i), 987, and 989(c), and 7701(f).
Section 1.861-9T also issued under 26 U.S.C. 861, 863(a), 864(e), 864(e)(7), 865(i), …
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
…hority:
26 U.S.C. 7805 * * *
* * * * *
Section 1.861-8T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f).
Section 1.861-9 also issued under 26 U.S.C. 861, 863(a), 864(e), 864(e)(7), 865(i), 987, and 989(c), and 7701(f).
Section 1.861-9T also issued under 26 U.S.C. 861, 863(a), 864(e), 864(e)(7), 865(i), …
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
IRCCourt RulingsOct 19, 1981
…es to Gain Tax Advantages,” 57 Taxes 797 (1979)] * * * at 802. [Foglesong v. Commissioner, 621 F.2d 865, 873 (7th Cir. 1980), revg. and remanding a Memorandum Opinion of this Court.]
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
IRCCourt RulingsApr 26, 2005★ strong match
t, as follows:
(a) General: Disposition of an action for
declaratory judgment which involves the initial
qualification of a retirement plan * * * will ordinarily be made on the basis of the administrative
record, as defined in Rule 210(b)(12). Only with the
permission of the Court, upon good cause shown, will
any party…