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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   4131/1962 and Provisional Measure No. 2224, dated September 4, 2001, if the licensee made an unauthorized remittance by either (a) making payments to a foreign person (controlling or noncontrol ling) without prior recordation of an agreement required to be recorded at the BPTO, or (b) making payments to a foreign cont…
2. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
   IRCCourt RulingsAug 4, 1983
   …hat its use is merely incidental thereto.” Fairfax Mutual Wood Products Co. v. Commissioner, 5 T.C. 1279, 1282 (1945) (involving the manufacture of furniture parts to the specifications of customers).
3. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003related by meaning
   f section 6501, 1 section 6651(a)(1), 2 - 37 - 2 (...continued) (2003) ; Janpol v. Commissioner , 102 T.C. 499, 503, 505 (1994); Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, aff…
4. 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…
5. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsJan 17, 2024related by meaning
   ccord Grajales, 156 T.C. at 58– 59 ( same). Section 4973 does not appear in C hapter 68, Subchapter A , captioned “Additions to the Tax and Additional Amounts .” T he exaction it imposes is therefore not an “a dditional amount” within the meaning of section 6751(c). To implement the foregoing, An order will be issued g…
6. T.C. Memo. 2013-271 — Christine C. Peterson & Roger V. Peterson v. Commissioner
   IRCCourt RulingsNov 25, 2013
   …e unambiguous agreements or show that they were unenforceable. See Plante v. Commissioner, 168 F.3d 1279, 1280-1281 (11th Cir. 1999), af_f'g T.C. Memo. 1997-386; Commissioner v. Danielson, 378 F.2d 771, 775 (3d Cir. 1967), vacating and remanding 44 T.C. 549 (1965). Accordingly, the 2009 FSP and GFP distributions are su…
7. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
   IRCCourt RulingsMar 20, 1997related by meaning
   but did not." Central Tablet Manufacturing Co. v. United States , 417 U.S. 673, 690 (1974); Commissioner v. National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149 (1974). It would be quite intolerable to pyramid the existing complexities of tax law by a rule that the tax shall be that resulting from the for…
8. T.C. Memo. 2000-266 — Lester L. & Susan P. Samford v. Commissioner
   IRCCourt RulingsAug 24, 2000
   … partnership’s taxable year begins upon the date it is formed. See Sparks v. Commissioner , 87 T.C. 1279, 1282 (1986). A partnership is formed “when the parties to a venture join together capital or services with the intent of conducting presently an enterprise or business.” Id. Whether SLA was formed prior to Septembe…
9. T.C. SUMMARY OPINION 2020-10 — James H. Dunlap & Eileen M. Dunlap v. Commissioner
   IRCCourt RulingsFeb 18, 2020
   …iguous agreements or show that they were unenforceable. See Plante v. Commissioner, 168 F.3d - 12 - 1279, 1280-1281 (1 lth Cir. 1999), afg T.C. Memo. 1997-386; Commissioner v. Danielson, 378 F.2d 771, 775 (3d Cir. 1967), vacating and remanding 44 T.C. 549 (1965). Accordingly, the 2009 FSP * * * distributions are subjec…
10. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004related by meaning
    nd v. Commissioner , 89 T.C. 1137, 1146 (1987): The language and legislative history of ERISA indicate a congressional intention to create, in section 4975(c)(1), a blanket prohibition against certain transactions, regardless of whether the transaction was entered into prudently or in good faith or whether the plan ben…
11. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
12. 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…
13. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    years beginning after the date of enactment of the Act); id. § 311(b)(2), 136 Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received). “This is the highly reticul…
14. T.C. Summary Opinion 2003-103 — Santos M. & Ingrid I. Castillo v. Commissioner
    IRCCourt RulingsJul 24, 2003related by meaning
    1 Unless otherwise indicated, section references hereafter are to the Internal Revenue Code in effect for the year at issue. T.C. Summary Opinion 2003-103 UNITED STATES TAX COURT SANTOS M. AND INGRID I. CASTILLO, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4698-02S. Filed July 24, 2003. Sant…
15. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
16. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
17. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
18. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
19. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
20. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    e year 2005 existed on the first day of 2005 and throughout that year. - 23 - On the record before us, we fmd that the date on which the Secretary was notified under section 4979A(e)(2)(D) of the ownership that gives rise to the excise tax under section 4979A(a) for petitioner's taxable year 2005 was later than that ow…