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1. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
   IRCCourt RulingsAug 30, 2006related by meaning
   or was the filing fee paid. See Rule 173(a). The Court ordered petitioners to file a proper amended petition and pay the filing fee by May 2, 2003. 13 Petitioners timely filed an amended petition with the Court and paid the filing fee. In the amended petition, petitioners disputed deficiencies determined for taxable ye…
2. 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…
3. 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…
4. T.C. Memo. 2012-13 — John K. Goyak & Associates, Inc. v. Commissioner
   IRCCourt RulingsJan 11, 2012
   …tal to the extent of the shareholder's basis in his stock. Truesdell v. Commissioner, 89 T.C. 1280, 1294-1295 (1987). Any amount received in excess of both the earnings and profits of the corporation and the shareholder's basis in his stock is treated as gain from the sale or exchange of property. Id. By the end of 200…
5. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
   IRCCourt RulingsOct 3, 1995★ strong match
   …hers. Zimmerman v. Commissioner , 71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner , 59 T.C. 456, 458 (1972). A fortiori, explications of such publications by a Maryland State agency are - 14 - 12 We observe that the IRS publications and the explications there…
6. T.C. Memo. 1999-352 — Luisa Deal v. Commissioner
   IRCCourt RulingsOct 25, 1999
   …. See Zimmerman v. Commissioner , 71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner , 59 T.C. 456, 458 (1972). Additionally, in order to ensure uniform enforcement of the tax law, the Commissioner must follow authoritative sources of Federal tax law and may cor…
7. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
   IRCCourt RulingsApr 19, 1989related by meaning
   e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
8. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
   IRCCourt RulingsAug 12, 1998
   …5th Cir. 1982); see also Threlkeld v. Commissioner , 848 F.2d 81, 84 (6th Cir. 1988), affg. 87 T.C. 1294 (1986); Propstra v. United States , 680 F.2d 1248, 1256-1257 (9th Cir. 1982). (continued...) those employees or beneficiaries. "[T]he phrase 'purposes other than for the exclusive benefit of his employees or their b…
9. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
   IRCCourt RulingsMar 16, 1999related by meaning
   ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
10. T.C. Summary Opinion 2001-168 — Mary Holland Trull v. Commissioner
    IRCCourt RulingsOct 23, 2001
    …Zimmerman v. Commissioner , 71 T.C. 367, - 6 - 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979). It is the relevant language of the Internal Revenue Code which must be followed. We find that petitioner was an active participant in an employer pension plan and hold that, because her adjusted gros…
11. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
12. T.C. Memo. 1996-278 — Donald G. Russell v. Commissioner
    IRCCourt RulingsJun 17, 1996
    …ions. Zimmerman v. Commissioner , 71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner , 59 T.C. 456, 458 (1972). Publications by the IRS, like the one on which petitioner relied, are merely guides published by the IRS to aid taxpayers. Dixon v. United States , 38…
13. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
14. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
15. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990
    …ccordance with his or her fiduciary responsibilities. See Estate of Graves v. Commissioner, 92 T.C. 1294, 1302-1303↩ (1989).
16. T.C. Memo. 2000-156 — Phillip M. Wenger, C.P.A., a Sole Proprietor v. Commissioner
    IRCCourt RulingsMay 12, 2000
    …. See Zimmerman v. Commissioner , 71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner , 59 T.C. 456, 458 (1972); see also Dixon v. United States , 381 U.S. 68, 73-75 (1965); Adler v. Commissioner , 330 F.2d 91, 93 (9th Cir. 1964), affg. T.C. Memo. 1963-196; Carte…
17. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    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…
18. T.C. Summary Opinion 2002-30 — Gregory Scott West v. Commissioner
    IRCCourt RulingsApr 1, 2002
    …rces. Zimmerman v. Commissioner , 71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner , 59 T.C. 456, 458 (1972). Additionally, in order to ensure uniform enforcement of the tax law, the Commissioner must follow authoritative sources of Federal tax law and may cor…
19. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner. Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
20. T.C. Summary Opinion 2006-55 — Linda L. & Anthony M. Domanico v. Commissioner
    IRCCourt RulingsApr 19, 2006
    …ble year. * * * v. Commissioner , 71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979). Second, section 72(t)(1) imposes an additional tax on distributions from a “qualified retirement plan” equal to 10 percent of the portion of such amount that is includable in gross income unless the …