T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 23, 2022
…ounting. On its original 2012 tax return, Hoops: (1) did not claim an ordinary
deduction of $10,673,327 relating to the deferred compensation liability,
(2) did not reduce its amount realized on the sale by $10,673,327 for the
deferred compensation liability, and (3) did not adjust its basis in any
property it owned as…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…cted future cashflows that
the property would generate. See, e.g. , Chapman Glen Ltd. , 140 T.C. at
327; Marine v. Commissioner, 92 T.C. 958, 983 (1989), aff’d , 921 F.2d
280 (9th Cir. 1991) (unpublished table decision). This approach is most
IRCCourt RulingsFeb 22, 2010
…der charge, the entire cash value of the insurance
policy for purposes of section 402(a) was $1,368,327 .33--the same
amount that respondent asserts as the policy's fair market value .
A valuation of $1,368,327 .33 is strongly, supported by the
fact that Hartford Life credited the trust with a $1,368,327 .33
premium pa…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…ected future income from the
property. See, e.g. , Chapman Glen Ltd. v. Commissioner, 140 T.C. 294,
327 (2013) . Income-based methods are not favored when valuing vacant
land with no income-producing history because they are inherently
speculative and unreliable. Ranch Springs, 164 T.C. at 135 (citing
Chapman Glen Ltd.…
IRCCourt RulingsOct 10, 1979related by meaning
Tannenwald, Judge:
Respondent determined deficiencies in the Federal income tax of petitioner for 1971, 1972, and 1973 in the respective amounts of $3,576.58, $4,052.04, and $3,912 together with negligence penalties under section 6653(a). The negligence penalties have been conceded by respondent, and capital loss adjus…
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…
IRCCourt RulingsOct 1, 2025
lan totaled $4,327,505. However, the attachments referenced in
the Letter indicate that the total benefits paid out as part of the Plan ’s termination totaled $4,327, 005, which is a difference of $500. This discrepancy is inconsequential ;
for purposes of this Opinion, we will refer to the latter number (i.e., $4,327,…
IRCCourt RulingsJan 14, 2013★ strong match
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 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…lth plan.[326]
The Department further assumes a wage rate of $181.06 per hour for the legal review [327]
and that this burden would only be incurred in the first year. The Department requests comments on these assumptions.
IRCCourt RulingsJun 17, 1997
…991
1992
Total income $440,673 $571,125 $672,543 $622,323 $639,859
Compensation of officers 164,000 327,000 450,000 315,000 367,000
Salaries & wages 86,551 36,600 42,656 23,247-0 -
Pension, profit-sharing, plans 73,462 77,769 93,556 160,351 102,506
Employee benefit programs 17,368 56,230 6,761 9,418 5,425
Taxable loss …
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…
IRCCourt RulingsMay 19, 1986related by meaning
urt has taken in later cases, such as those noted earlier herein, is a matter that we need not consider. The plain fact is that it is distinguishable. We find support, at least to some extent, for our conclusion that the provision under attack is constitutional in the numerous recent cases interpreting section 2035 wit…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsNov 7, 1996
…distributions in the gross amount of $348,641 (i.e., $348,483 +
$158) and in the taxable amount of $327,814 (i.e., $327,656 +
$158). The parties have stipulated that the $158 distribution,
as well as the Transfer Refund (in the amount of $348,483), was
received from the Retirement System. However, the record does
not d…
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 RulingsApr 11, 2012★ strong match
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
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. …
IRCCourt RulingsMay 23, 1979related by meaning
oner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960). For all of the above reasons, we have no difficulty in holding that the pension plan contribution made by petitioner’s wholly owned subchapter S corporation and deducted…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsJan 30, 2007
…249,931 805,603 Based on Exhibit II, petitioners reported total taxable IRA
. distributions of $444,327. Petitioners also reported total
pension distributions of $372,850, reflecting the distribution
from Plan 15104, 'but they determined that only $192,850 was
taxable. After including interest income, dividend income, …