Case law

Juda v. Commissioner

90 T.C. 1263 · United States Tax Court · Jun 27, 1988

CAMBRIDGE shall have the right to terminate this Agreement at any time if, based on its own judgment, the FIRE DRILL does not conform to its standards or criteria for the establishment of a successful venture based on the … The x-ray film shows a composite image of the heart, timed to capture the heart movement from its fuby expanded to its fuby contracted state, thereby clearly displaying abnormahties in pumping contractions.

Dunlap v. Comm'r

103 T.C.M. 1689 · United States Tax Court · May 1, 2012

Miller was a qualified appraiser and the appraisal was a qualified appraisal. … Miller’s appraisal clearly identified the method of valuation as the market data analysis approach.

Lily Hilda Soltani-Amadi & Bahman Justin Amadi v. Commissioner

2019 T.C. Summary Opinion 19 · United States Tax Court · Aug 8, 2019

Such an evidentiary foundation exists in the present case, as the record clearly demonstrates that Ms. … Thus, the section 401(k) retirement plan established by the State of New York for the benefit of its employees such as Ms.

Estate of Susan R. Block, Julie B. Saffir and Peter A. Block, Executors

United States Tax Court · Mar 13, 2023

The Estate does not contend, and the evidence does not establish, that the burden of proof shifts to respondent under section 7491(a) as to any issue of fact. … Yet the exception for judicial reformations clearly does not apply here.

Graham v. Commissioner

46 T.C. 415 · United States Tax Court · Jun 23, 1966

Petitioner is the duly qualified executor of the Estate of James H. Graham, who died a resident of Jefferson County, Ky., on June 24, 1960. The U.S. … In that case, the decedent had established a trust for the benefit of his daughter, the corpus to be paid to her when she attained age 30.

Bausch & Lomb, Inc. v. Commissioner

92 T.C. 525 · United States Tax Court · Mar 23, 1989

(Allied) entered into a loan agreement that qualified under section 84, pursuant to which B&L Waterford borrowed from Allied $4,200,000, and concurrently loaned the money to B&L Ireland. … Therefore, the third party purchase agreements identified by petitioner qualify as comparable-uncontrolled-sales for purposes of application of the comparable uncontrolled price method.

Merino v. Comm'r

106 T.C.M. 36 · United States Tax Court · Jul 16, 2013

In the case of a joint return, a spouse must separately satisfy the requirements of section 469(c)(7) to qualify as a real estate professional. Id. … Petitioners also do not qualify for the limited exception under section 469(i).

Morgan v. Commissioner

37 T.C.M. 1661 · United States Tax Court · Oct 5, 1978

Ronald and Carol were also established as lifetime trustees and the trust was designated as an educational trust. … The record, however, clearly establishes that the disputed amount was paid for the purely personal objective of changing the form in which title to petitioners' property was held and as such is a nondeductible expenditure

Gill v. Commissioner

65 T.C.M. 2993 · United States Tax Court · Jun 24, 1993

Petitioner bears the burden of establishing that each element has been satisfied. . There is no dispute that a joint return was filed. … Petitioner clearly satisfies this requirement as the understatements in this case range from $ 3,545 to $ 7,174. Respondent contends that petitioner has not established that the deductions claimed by Mr.

Lane-Burslem v. Commissioner

70 T.C. 613 · United States Tax Court · Aug 3, 1978

Petitioner contends that this statute permits a woman to establish a separate domicile apart from that of her husband. … Clearly, Louisiana law does not have any effect over Eric’s earnings and would not give petitioner one-half of his earnings.

Ford Dealers Advertising Fund, Inc. v. Commissioner

55 T.C. 761 · United States Tax Court · Feb 22, 1971

It involved the purchase and presentation of U.S. savings bonds of $18.75 denomination to qualifying salesmen of various dealers, with Advertising paying $10 per unit and the dealer $8.75. … While petitioner had the right to receive the bottlers’ contributions under its agreements with them, all the facts and circumstances surrounding the transaction clearly Indicate that it was the intention of all of the parities

Collins v. Commissioner

40 T.C.M. 233 · United States Tax Court · Apr 23, 1980

These sections of the United States Code set forth the procedures for according "use immunity" to certain witnesses, Tierney v. … As observed above in the text of this Opinion, the 1975 document clearly was not a return within the meaning of the Code.

Suder v. Comm'r

108 T.C.M. 354 · United States Tax Court · Oct 1, 2014

Petitioners argue that ESI clearly had in place a very detailed, multi-level, systematic process for development of all facets of its phone systems which involved 1) conceptually hypothesizing how numerous … The vast amount of planning, testing, and bug fixing documentation in the record establishes that ESI did not know the appropriate design of any of the 12 products at the outset.

J L Minerals, LLC, Beasley Timber Management, LLC, Tax Matters Partner

United States Tax Court · Oct 8, 2024

Held: J made a qualified conservation contribution under I.R.C. § 170(h) and attached to its return a qualified appraisal by a qualified appraiser under I.R.C. § 170(f)(11) and Treas. … The Commissioner asserts that JL Minerals failed to obtain a qualified appraisal or to retain a qualified appraiser. A.

Providence Wool Combing Co. v. Secretary of War

14 T.C. 979 · United States Tax Court · May 31, 1950

Nevertheless, the petitioner failed to offer any evidence to support, explain, or qualify the stipulations it made, as set forth above and in the findings of fact. … state in which it is customarily sold or in which it has an established market.

Waldron v. Comm'r

102 T.C.M. 583 · United States Tax Court · Dec 15, 2011

A taxpayer who does not qualify for relief under section 6015(b) or (c) can qualify for relief under section 6015(f) if, 9 Respondent argues vigorously on brief that we should review the Appeals officers’ determinations … This payment arrangement lasted for 3 years, when for reasons not clearly explained by the record, the payments stopped.11 Because the signing of the joint returns in question and the securing of the installment

Globe Products Corp. v. Commissioner

72 T.C. 609 · United States Tax Court · Jul 5, 1979

In our judgment she is not entitled to a deduction which would, either directly or indirectly, reduce the * * * [tax] which she clearly owes. … However, if a taxpayer contests or denies his liability during a taxable year, there is no proper accrual until the liability is finally established. See, e.g., Security Flour Mills Co. v.

South Fulton Parkway 58, LLC, South Fulton 58 Manager, LLC, Tax Matters Partner

United States Tax Court · May 4, 2026

Section 170(h)(1) specifies that such a contribution must be (1) of a qualified real-property interest, (2) to a qualified organization, and (3) exclusively for conservation purposes. See also Atkinson v. … (CCH) at 562 (mentioning state law does not establish clearly delineated policy).

Estate of Sommers v. Comm'r

149 T.C. No. 8 · United States Tax Court · Aug 22, 2017

The estate, however, had failed to establish the value of those contribution rights, and the record was insufficient for us to make that determination on our own. … Estate of Morgens dealt not with a net gift but instead a surviving spouse's gift of qualified terminable interest property (QTIP).

Genecure, L.L.C., Frank Y. Tung, Tax Matters Partner

United States Tax Court · May 23, 2022

2009 By extension, members of the LLC are treated analogously to partners in a 10 partnership. 11 Therapeutic vaccines are nonprophylactic and are designed to treat diseases by eliciting an immune … Glenshaw Glass Co., 348 U.S. 426, 431 (1955) (holding that gross income includes any accession to wealth, clearly realized, over which the taxpayer has complete dominion).