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Tax and IRS

Products (Total Items: 15 )
Commissioner v. Banks
Damages, including contingent fee amounts, are taxable income to litigants; a taxpayer may not anticipatorily assign the income to avoid tax liability for the income. Agent assignment contingent fee ordinary income principal.
King v. Commissioner
Noncustodial parents; dependency exemption deduction; lived apart from his child; last six months, receives more than half of his support from his parents during the year; custodial parent signs a written declaration.
Churchill Downs, Inc. v. Commissioner
Costs of invitation-only events used to publicize the kentucky derby are entertainment expenses; deductions for activities generally considered entertainment are limited to fifty percent, unless objectively integral to taxpayer business or occupation.
IHC Health Plans, Inc. v. Commissioner of Internal Revenue
Organization will not be considered charitable unless it is operated primarily to serve public rather than private interest.
IHC Health Plans, Inc. v. Commissioner of Internal Revenue
Organization that is not itself tax-exempt may become tax-exempt if it operates solely to provide goods or services to exempt organizations that are essential to the operation of that exempt organization.
Tax Reform
Congressional regulations; tax code.
Internal Revenue Code
Tax regulation; IRS regulations cartoon.
Money Subject to Repayment Contingency Is Not Gross Income
Westpac Pacific Food v. Commissioner; Cash advances in exchange for volume purchase commitments, subject to pro rata repayment if the volume commitments are not met, are not gross income when received; accrual basis.
Substitute For Ordinary Income Doctrine
Womack v. Commissioner; Under the substitute-for-ordinary-income doctrine, when a party receives a lump-sum payment for what otherwise would have been received, at a future time, as ordinary income, that lump sum payment isordinary income.
Property Settlement In Divorce Is Not A Taxable Event
Young v. Commissioner; A transfer of property is "incident to a divorce," and is thus a nontaxable event, if it is related to the cessation of the marriage; basis; nonrecognition rule.
Taxes On Lottery Winnings
Watkins v. Commissioner; under the substitute-for-ordinary-income doctrine, lump sum payments received in exchange for future time ordinary income is ordinary income because not for increased value of income-producing property.
Taxability of Student Income
Mayo Foundation for Medical Education and Research v. United States. Chevron analysis, not National Muffler analysis, applies in student income tax cases and social security tax issue. Chevron Deference.
Hobby Loss Rule
Engdahl v. Commissioner. When a taxpayer engages in an activity with the bona fide purpose of turning a profit, losses incurred from that activity are fully deductible. Horse breeding. Deductibility of business losses.
Sale Or Exchange
Bloomington Coca-Cola Bottling Co. v. Commissioner; The presence of a small amount of cash, to adjust certain differences in value of the properties exchanged, does not necessarily prevent the transaction from being considered an exchange.
Acquisition Indebtedness
Sophy v. Commissioner; The limitations on the amounts that may be treated as acquisition and home equity indebtedness with respect to a qualified residence are properly applied on a per-residence rather than per-person basis.