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64 documents · 0.48sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    efinition of an applicable foreign legal restriction and the taxpayer has elected the deferred income method of accounting, any section 482 allocation connected with the transaction will be defer rable until the restriction is removed. Deductions and credits chargeable against a deferred amount are subject to deferral …
  2. 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…
  3. T.C. Memo. 1997-34 — Mark J. & Mary A. Fuhrman v. Commissioner
    IRCCourt RulingsJan 21, 1997
    …ase, focused precisely on this point in Porter v. Commissioner , 88 T.C. 548 (1987), revd. 856 F.2d 1205 (8th Cir. 1988), affd. on other grounds sub nom. Adams v. Commissioner , 841 F.2d 62 (3d Cir. 1988). In Porter v. Commissioner , supra , we considered whether for purposes of section 219(g), Federal judges appointed…
  4. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    … objective of making a profit. Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), aff ’ d , 702 F.2d 1205 (D.C. Cir. 1983) (unpublished table decision) ; Golanty v. Commissioner, 72 T.C. 411, 425 – 26 (1979), aff ’ d , 19 We direct Mr. Janangelo’s attention to Treas ury Reg ulation § 1.212- 1(f): “ Among expenditures no…
  5. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  6. T.C. Memo. 2021-107 — Gayle Gaston v. Commissioner
    IRCCourt RulingsSep 2, 2021
    … 183; Dreicer v. Com m issioner, 78 T.C. 642, 645 (1982), aff’d without published opinion, 702 F.2d 1205 (D.C. Cir. 1983); see also sec. 6001; sec. 1.6001-1(a), Incom e Tax Regs. Respondent has conceded - 8 - [*8] that petitioner actually paid the reported expenses. We therefore m ust determ ine only whether the expens…
  7. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
    IRCCourt RulingsAug 13, 1999related by meaning
    penses which are ordinary and necessary and recurring in nature. Respondent relies on Rev. Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring expenses paid by an employer are not deductible under this regulation. We disagree. Our analysis starts at s…
  8. 46 T.C. 706 — Schlegel v. Commissioner
    IRCCourt RulingsAug 31, 1966
    …2d 613 (C.A. 7, 1960) ; William S. Bolden, 39 T.C. 829 (1963) ; Estate of Edward I. Rieben, 32 T.C. 1205 (1959) ; Clarence F. Buckley, 29 T.C. 455 (1957). Where, however, there is a change of employer accompanied by such a transfer of beneficial ownership, the requirement is met, at least where the acquiring new employ…
  9. 148 T.C. No. 22 — Steven M. Petersen & Pauline Petersen v. Commissioner
    IRCCourt RulingsJun 13, 2017
    …onding inclusion in income." H.R. Rept. No. 98-432 (Part 2), at 1578 (1984), 1984 U.S.C.C.A.N. 697, 1205. -14Section 267(b) generally defines the "relationships" that bring the statute into play. Before 1978 transactions between S corporations and their shareholders were exempt from its coverage unless the shareholder …
  10. T.C. Memo. 2000-137 — Alton F. Emerson v. Commissioner
    IRCCourt RulingsApr 12, 2000
    …(1983); Dreicer v. Commissioner , 78 T.C. 642, 645 (1982), affd. without published opinion 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs. While a taxpayer's expectation of profit need not be reasonable, there must be a good-faith expectation of making a profit. See Allen v. Commissioner , 72 T.C. 28,…
  11. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
  12. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996
    …W. AND SUZANNE M. COFFIELD, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1205-95. Filed August 8, 1996. Timothy W. and Suzanne M Coffield, pro se. Mark S. Mesler , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Carleton D.…
  13. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  14. PBGCPBGC Opinion LettersMay 20, 1998
    …d their compensation and discharge . . . ." S ee A ll ey v. Resolut ion Trust Corp., 984 F.2d 1201, 1205-6 (D.C. Ci r. 1993) (cour t foun d no indica tion t hat Cong ress meant the ERISA exem ption to reach an ent it y whos e em ploye es are not sub ject to la ws go vernin g pub lic employees gener ally, since " the co…
  15. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  16. 29 C.F.R. § 2570.63 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(2) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  17. T.C. Memo. 1996-146 — Lloyd Patterson v. Commissioner
    IRCCourt RulingsMar 25, 1996
    …making a profit." Dreicer v. Commissioner , 78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983). The taxpayer's expectation of earning a profit need not be reasonable, but the taxpayer must establish that the activities were continued with a bona fide profit objective. Dreicer v. Commissioner …
  18. T.C. Memo. 2012-311 — Charles L. Hartley v. Commissioner
    IRCCourt RulingsNov 6, 2012related by meaning
    oneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). However, the Commissioner bears the burden of proof with respect to any increase in deficiency. See Rule 142(a)(1). Our conclusion, however, is based on a preponderance of the evidence, and thus the allocation of the burden of proof is immaterial. See E…
  19. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …st. Dreicer v. Commissioner, 78 T.C. 642, 644-645 (1982), aff'd without published opinion, 702 F.2d 1205 (D.C. Cir. 1983); sec. 1.183-2(a), Income Tax Regs. Whether a taxpayer has an actual and honest profit - 10 - [*10] objective is a question of fact to be answered from all of the relevant facts and circumstances. Ha…
  20. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013related by meaning
    s amount includes the additional tax of $32,137 under sec. 72(t). - 27 - [*27] that the determination of reasonable cause and good faith "is made on a case-by-case basis, taking into account all pertinent facts and circumstances." Sec. 1.6664-4(b)(1), Income Tax Regs. The parties have agreed in the stipulation of settl…