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75 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 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…
  2. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    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…
  3. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    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…
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  5. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    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…
  6. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    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…
  7. 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
  8. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    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…
  9. T.C. Summary Opinion 2014-94 — Kenneth Russell Laremore v. Commissioner
    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…
  10. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    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…
  11. 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), …
  12. 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), …
  13. 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 .
  14. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    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…
  15. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  16. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  17. T.C. Memo. 2015-47 — Balvin Anthony McKnight v. Commissioner
    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…
  18. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    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.]
  19. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    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…
  20. 124 T.C. No. 12 — Charles P. Stepnowski v. Commissioner
    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…