167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…he net present value of a hypothetical limestone business
conducted on the land. See Ranch Springs, 164 T.C. at 151– 53;
Beaverdam Creek , T.C . Memo, 2025- 53, at *36. Even if we were to
conclude that the highest and best use of the Property w as as a
limestone mine, Mr. Catlett’s before value of $34,540,000 would fai…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
164 T.C. at 151.
When applied to vacant land, the approach can be highly sensitive to
assumptions, and unsupported projections have undermined income an alyses in many conservation easement cases. See, e.g., Savannah
Shoals, T.C. Memo. 2024-35, at *36 (“Income valuation methods are not
favored when valuing vacant land…
IRCCourt RulingsDec 29, 2005★ strong match
… raising this issue when this case was called
for trial.
A
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that are deductible under section 164(a)(1);' i.e., that were
imposed on her interest in real property and that such taxes were
levied for the general public welfare, sec. 1.164-3(b), Income
Tax Regs. Absent that evidence, we hold that petitioner is not
…
IRCCourt RulingsJul 27, 2004
… Real Estate Excise Tax
The first issue is whether petitioners are entitled to
deduct under section 164(a)(1) the Washington State real estate excise tax that they paid on the sale of their residence.
As relevant herein, section 164(a) allows a deduction for
five specific categories of taxes, specifically including Sta…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…concluding that private investment markets may not provide reliable diversification to a portfolio.[164]
IRCCourt RulingsFeb 9, 2023★ strong match
…163
Petitioner contends that the Brazilian legal
restrictions met some of these seven requirements.
164
We discuss
162 Title 26 C.F.R. sec. 1.482-1(h)(2)(ii)(A) (2006) requires that the foreign legal
restriction be “publicly promulgated, generally applicable to all similarly situated
persons (both controlled and uncont…
76 FR 49570 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests IRCFinal Rules (FR)Aug 10, 2011
…der the plan, determined as follows:
(A) Present value of S 's annuity: $73,958.40 × 11.0625 = $818,164.80.
(B) Annuity Factor for Expected Annuity Term: $818,164.80/$73,958.40 = 11.0625.
(iii) The second step is to determine the number of years that would be required for S 's annuity to exhaust a hypothetical fund of …
IRCProposed Rules (FR)Proposed Nov 27, 2019
…for any subsequent use or disclosure of the requested ePHI received by the app.”). See also,
45 CFR 164.524(a)(1), (c)(2)(ii), and (c)(3)(ii).
Back to Citation
71.
See https://www.hhs.gov/hipaa/for-professionals/faq/2037/are-there-any-limits-or-exceptions-to-the-individuals-right/index.html.
See also, 45 CFR 16…
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…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua… IRCTreasury DecisionsMar 7, 2016related by meaning
ses of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2016.
Rev. Proc. 2016–16 Rev. Proc. 2016–16 General Rules and Specifications for Substitute Form 941, Schedule B (Form 941), Schedule D (Form 941), and Schedule R (Form 941) This procedure provides general rules a…
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…
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
…e.
See § 1026.43(d)(2)(iv) and (v).
Back to Citation
67.
See
OCC: 12 CFR parts 34, Subpart C, and 164; Board: 12 CFR part 208, subpart E, and part 225, subpart G; FDIC: 12 CFR part 323; NCUA: 12 CFR part 722.
See also75 FR 77450 (Dec. 10, 2010).
Back to Citation
68.
FDIC: 12 CFR part 323; FRB: 12 CFR part 208, subpa…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
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 RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsOct 16, 2001
…deduction on their
1998 Federal income tax return in the amount of the additional tax under section 164.
The tax for which the deduction here is claimed arises under
section 72(t). Section 72(t) provides that if a taxpayer
receives a distribution from a qualified retirement plan “the
taxpayer’s tax under this chapter *…
IRCCourt RulingsMar 24, 2000
… property taxes on her 1993 and 1994 Federal
income tax returns.
C. Personal Property Taxes
Section 164(a)(2) permits deductions for State and local
property taxes. Under section 164(b)(1), property taxes are
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6
Petitioner also contends that she is entitled to deduct
smog certification expenses and driver’s licens…
IRCCourt RulingsJun 18, 1999related by meaning
1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard,…
IRCCourt RulingsJan 30, 2007
… that petitióners are not entitled to deduct the remaining
expenses, including: (1) $909 of the $20,164 identified by
petitioners as "Opt.int" for "Merrill Lynch"; (2) $13,076 of the
$26,000 identified by petitioners as "US Bank Fees"; (3) $330,979
and $123,000, identified by petitioners as "Cash Pay" and
described as …