IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsJun 29, 1977
…s from his salary in the amount of $16,525.57 and his employer’s contributions made before 1939 of $595.80. His individual annuity savings account had also been credited with interest on the accumulated contributions totaling $18,130.62. Of such amount, $76.81 represented interest earned between September 1, 1933, and …
IRCCourt RulingsMay 19, 2011
…Whether Weekend Warrior is entitled to
management fee deductions lof $4,175,000, $4,800,000, and
$4,595,000 for 2002, 2003, and 2004, respectively, (2) whether
Weekend Warrior is entitled to depreciation deductions with
respect to the airplane and the Nordic boat (boat), (3) whether
Weekend Warrior is entitled to airpl…
IRCCourt RulingsFeb 9, 2023related by meaning
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…e 16092)
an ERISA fiduciary will implicate difficult tradeoffs.”
Hughes
v.
Northwestern University, 595 U.S. 170, 177 (2022). And, as discussed above, a fiduciary must act based on “the circumstances as they reasonably appear to [the fiduciary] at the time when he does act and not at some subsequent time when his condu…
IRCCourt RulingsMar 31, 1997
…ngs between the parties; and lack of assets. American
Offshore, Inc. v. Commissioner
, supra
at 594-595. No single factor is conclusive. Id.
at 595.
We conclude that petitioner has failed to meet his burden of
proving the worthlessness of the debt during the year in
question. Petitioner presented scant evidence concern…
IRCCourt RulingsJul 30, 2007
…formation, respondent determined
that in 2000 petitioner received : (1) Wage income of $12,733,
$10,595, $4,716, $44,250, $14,271, and $9,279, from Metro
IRCCourt RulingsJun 9, 1965
…struction in process_ 11,817.18 56,524.90 3,782.24 993.93 95,609.24 2,567,82 2,442.28 325.92 528.42 595.44 25,686.90 116,631.86 7,804.16 2,050.85 197,277.36 5,298.36 5,039.74 672.50 1,090.33 595.44
175,187.67 362,147.50
OPINION RE ISSUE 1
We must decide under this first issue whether the petitioner has sustained its bu…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
IRCCourt RulingsFeb 25, 2016
…avel expenses of $274,830 and meals and entertainment
expenses of $24,250, for a net profit of $116,595. Petitioner reported Strategies'
income of $116,595 on a Schedule E attached to his 2005 Form 1040.
V. Notices of Deficiency
On June 9, 2011, respondent issued a notice of deficiency to petitioner for
2004.6 Responde…
IRCCourt RulingsApr 26, 2005
…422; see also Stevens v. Commissioner, T.C. Memo. 1985-192; Wenzel v. Commissioner, T.C.
Memo. 1982-595, affd. 707 F.2d 694 (2d Cir. 1983). Rather, in a
declaratory judgment action under section 7476, we must decide
whether the Commissioner, in making a determination as to the
- 11 -
initial or continuing qualification…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
ERISACourt RulingsAug 17, 2026
…ve yielded, would not (or could not)
have made the same choice.” Id. ( quoting Hughes v. Nw. Univ., 595
U.S. 170, 177 (2022) ).
ERISA plaintiffs often rely on compar isons to demonstrate
objective imprudence by presenting evidence that a challenged investment was inferior to an alternative that a fiduciary could have
c…
T.C. Memo. 1998-64 — Reed Smith Shaw & McClay; William J. Smith, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 17, 1998
… place:
- 13 -
Number Price
Date
Trans.
of Shares
Per Share
Cost
Proceeds
7/29/87 Sale 95 $6.25 -- $595.75
9/16/87 Purchase 5,000 9.00 $45,000 --
9/30/87 Purchase 5,000 10.25 51,252 --
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…usinesses or other for-profits, Not-for-profit institutions.
Respondents:
10,909,076.
Responses:
31,595,244.
Estimated Total Burden Hours:
263,294.
Estimated Total Costs:
$5,480,827.
Description:
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’ …
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…0s, which tended to have more generous benefits, particularly regarding minimum benefit guarantees.[595]
49 T.C. 174 — Armanco Productions, Inc. v. Commissioner IRCCourt RulingsDec 8, 1967related by meaning
dic or annual compensation on the basis of permanent employment;
(c) Are full-time employees who have not attained the age of seventy-five (75) years; (d) All personnel employed by the Company as of the effective date of this Trust shall be eligible to become Participants therein. All personnel employed subsequent to F…
IRCCourt RulingsMay 20, 1976related by meaning
he earned less than other dentists in the area but the best evidence of the value of his personal services is profit he derived from his own practice. As a final issue, we must decide whether the 5-percent addition to tax under section 6653(a) is applicable. In his statutory notice of deficiency, the Commissioner made …