Case law

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).

Daniel E. Larkin & Christine L. Larkin v. Commissioner

2020 T.C. Memo. 70 · United States Tax Court · May 28, 2020

The evidence the Larkins provided also fails to establish that the loan is for a qualified residence within the meaning of section 163. … Larkin clearly assumed the ultimate responsibility for the preparation of his returns. Because the Larkins have not met their burden to establish the relevant facts under Neonatology Assocs., P.A. v.

Murfam Enterprises LLC, Wendell Murphy, Jr., Tax Matters Partner

United States Tax Court · Jun 15, 2023

The FPAA included Form 886–A, “Explanation of Adjustments”, which stated: It has not been established that the value of the noncash charitable contribution of a Qualified Conservation Easement deducted … Section 170(h)(1) defines a “qualified conservation contribution” to be (1) the contribution of a “qualified real property interest,” (2) to a “qualified organization,” (3) “exclusively for conservation purposes.”

Akelis v. Commissioner

57 T.C.M. 213 · United States Tax Court · Apr 24, 1989

The principal amount of the note executed by KJP, however, failed to clearly correspond to the agreement; but rather obligated KJP to pay BMC $ 580,000. … For petitioners to properly claim ITC on property owned by KJP, they must establish that the property to which the credits relate was qualified as "section 38 property" in KJP's hands. *200 Section 702(b); section 1.702-1

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

Gage Bros. & Co. v. Commissioner

13 T.C. 472 · United States Tax Court · Sep 30, 1949

It was a continuation of an unincorporated business of similar character established in 1856. … There is a suggestion that the transaction does not qualify because Old Gage, rather than its stockholders and creditors, was the transferor.

Fowler v. Commissioner

48 T.C.M. 309 · United States Tax Court · Jun 20, 1984

Thus, we find that petitioner did not make any donations in 1979 and 1980 to an organization that qualifies under section 170(c)(2). … One of the primary reasons petitioner established his asserted church was to evade paying taxes.

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.

Transp. Labor Contract/Leasing, Inc. v. Comm'r

123 T.C. 154 · United States Tax Court · Aug 9, 2004

*DRTVER: The use of the word Driver refers to any company employees who have been qualified to drive for any of TLC, Inc.’s lessees. … Moreover, the record does not always clearly distinguish the roles of Beech Trucking and ATS with respect to the drivers activities. * * * Joe Hix was one of TLC’s trucking company clients. The court in Hix v. Minn.

Klaas v. Comm'r

97 T.C.M. 1467 · United States Tax Court · Apr 29, 2009

To establish fraud, respondent must prove (1) an underpayment exists, and (2) Mr. … Although these actions establish that Mr. Klaas sought to minimize his tax liability from the sale, none constitutes fraud. Clearly, Mr.

Edward J. Tangel & Beatrice C. Tangel

United States Tax Court · Jan 11, 2021

“In-house research expenses” include wages paid to employees who engage in (or directly supervise) qualified research and amounts paid or incurred for supplies used in the conduct of qualified research. … Paragraph 15(A) clearly covers the results of any research Enercon performs in the course of fulfilling the contract.

Jeffrey Tangel & Kathleen Tangel

United States Tax Court · Jan 11, 2021

“In-house research expenses” include wages paid to employees who engage in (or directly supervise) qualified research and amounts paid or incurred for supplies used in the conduct of qualified research. … Paragraph 15(A) clearly covers the results of any research Enercon performs in the course of fulfilling the contract.

Popa v. Commissioner

73 T.C. 130 · United States Tax Court · Oct 22, 1979

In the usual case, only one cause of loss is alleged and the issue either is whether that was the cause or whether that cause qualifies the loss for deduction. … Commissioner , 27 T.C. 455 , 462 (1956) , clearly involved a loss incurred in a transaction entered into for profit. In Solt v.

Gerald Landry & Colette Tangel

United States Tax Court · Jan 11, 2021

“In-house research expenses” include wages paid to employees who engage in (or directly supervise) qualified research and amounts paid or incurred for supplies used in the conduct of qualified research. … Paragraph 15(A) clearly covers the results of any research Enercon performs in the course of fulfilling the contract.

Lawrence E. Tangel & Karen S. Tangel

United States Tax Court · Jan 11, 2021

“In-house research expenses” include wages paid to employees who engage in (or directly supervise) qualified research and amounts paid or incurred for supplies used in the conduct of qualified research. … Paragraph 15(A) clearly covers the results of any research Enercon performs in the course of fulfilling the contract.

Budlong v. Commissioner

7 T.C. 756 · United States Tax Court · Sep 19, 1946

The petitioner is the duly qualified executor under the will of Milton J. Budlong, hereinafter referred to as the decedent, who died a resident of Newport, Rhode Island, on July 5, 1941. … Clearly, the decedent did not have free rein to expend the corpus or to give it to whom he chose.

Scar v. Commissioner

81 T.C. 855 · United States Tax Court · Nov 17, 1983

Ingling , 300 F.2d 859 (9th Cir. 1962) , cited by petitioners, is clearly distinguishable. … Thus, it is that, under the majority opinion, the following qualifies as a valid statutory notice of deficiency within the meaning of sections 6211 and 6212 of the Code.

Estate of Remington v. Commissioner

9 T.C. 99 · United States Tax Court · Jul 23, 1947

Remington, by the duly qualified executrix, filed the income tax return for the estate for the taxable period with the collector of internal revenue for the second district of New York. … Upon the return filed for the period in question petitioner, in order to qualify under the new law, gave the required "full consent" to make the amendments retroactively applicable.

FURNISS v. COMMISSIONER

81 T.C.M. 1741 · United States Tax Court · Jun 11, 2001

Under section 61(a)(1), (4), (7), and (11), and section 85(a), petitioner clearly is required to include in gross income all his receipts in the years in issue. … We allowed petitioner ample time to present evidence establishing these deductions.

Apache Corporation and Subsidiaries

United States Tax Court · Nov 13, 2025

Within that amount, Apache reported that $40,734,363 qualified as a specified liability loss within the meaning of section 172(f)(1). … Apache claimed that $30,818,137 of that amount qualified as a specified liability loss.