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1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   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…
2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   ...................................................................... 111 Y. Regulations 118 .................................................... 114 Z. The Internal Revenue Code of 1954 ..................... 115 AA. The 1960 notice of proposed rulemaking ............. 119 BB. The creation of a new title of the Code o…
3. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
   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…
4. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
   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…
5. 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…
6. 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…
7. 98 T.C. 503; 98 T.C. No. 34 — Fowler v. Commissioner
   IRCCourt RulingsApr 22, 1992related by meaning
   tatutoiy references are to the Internal Revenue Code in effect for 1986, and all Rule references are to the Tax Court Rules of Practice and Procedure. he parties have stipulated as follows: 8. During 1986, the petitioner, due to his termination of employment * * * received a total distribution from his employer's Incen…
8. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
   IRCCourt RulingsJan 20, 1983related by meaning
   e, and we must therefore uphold its validity. III. Petitioner’s Miscellaneous Contentions 1. Effective Date of Section 1.415-5(c)(l), Income Tax Regs. Section 1.415-1(f), Income Tax Regs., states that section 1.415-5(c)(l), Income Tax Regs., is effective for plan years beginning after 1975 and that, for all such plan y…
9. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
   IRCCourt RulingsFeb 18, 1997related by meaning
   l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
10. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987related by meaning
    GOFFE, Judge: The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
11. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
12. 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…
13. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    articipants, Harold Breslow and Robert Levine, received their full benefit and petitioner signed an irrevocable waiver of his rights to Plan benefits. We reject petitioner's argument. Examining the record, we find no documentary evidence that all rank and file employees were paid their full vested interest, especially …
14. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996related by meaning
    ................................. 9 MIT 80.................................................. 12 Formation of MIT 80................................ 12 Investors in MIT 80................................ 13 Organization and Management of MIT 80.............. 13 MIT 80 Employee Leasing Arrangement................ 14 Oper…
15. 57 T.C. 326 — Trebotich v. Commissioner
    IRCCourt RulingsDec 9, 1971related by meaning
    n will be entered under Rule 50. Drennen, /., dissents. All statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. In addition to the $7.4 million per year, $1.2 million was to be contributed by the employers over a 3-year period to pay benefits which had vested under the 196.1 agree…
16. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
17. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
18. T.C. Memo. 2011-253 — George R. Ward, Petitioner and Victoria J. Ward, Intervenor v. Commissioner
    IRCCourt RulingsOct 31, 2011related by meaning
    returns were filed. Sec. 6015(d) (2), (3) (A); sec. 1.6015-3(d) (4) (ii), Income Tax Regs. The 10-percent additional tax would have been allocated to George R. Ward, not Victoria J. Ward, if they had filed separate returns. George R. Ward received the distribution. As the recipient, he was the taxpayer who would have …
19. 49 T.C. 128 — Swofford v. Commissioner
    IRCCourt RulingsNov 28, 1967related by meaning
    tax return clearly show that he bases his contention that the $15,000 was entitled to capital gains treatment under sections 401 and 402, I.R.C. 1954. These statutes are not applicable. In general, section 401 sets forth the requirements for qualification of an employees’ trust or pension plan so that contributions of …
20. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…