§618

11 cases·1 followed·1 distinguished·1 overruled·8 cited9% support

Statute text not available for this section.

11 Citing Cases

OVERRULED Roosevelt Wallace, Petitioner 128 T.C. No. 11 · 2007

to enter 8(...continued) opinion designated as a precedent opinion is binding on Department officials and employees in subsequent matters involving a legal issue decided in the precedent opinion, unless there has been a material change in a controlling statute or regulation or the opinion has been overruled or modified by a subsequent precedent opinion or judicial decision.

Wallace v. Commissioner 128 T.C. 132 · 2007

V, 1962), a predecessor provision to section 1718. It holds that the receipt is a payment for services rendered even though it is intended for therapeutic or rehabilitative purposes, and, because it is a payment for services, it is included in the recipient’s gross income. III. Discussion A. Exemption We are faced with a question of

Daniel Feaster, Petitioner T.C. Memo. 2010-157 · 2010

Itemized deductions may be limited .under, section 618 and .may have alternative minimum ',taximplications,-,.- under section 56(b) (1) (A) (i ) An individual who :performs -services as .an` independent contractor is - entitled .

ts of the contract will be preferred to one that leaves portions of the contract meaningless." Rink V. Commissioner, 47 F.3d 168, 171 (6th Cir. 1995), affg. 100 T.C. 319 (1993); 2 Restatement, Contracts 2d, sec. 202 (1981); 4 Williston on Contracts, sec. 618 (3d ed. 1961). Petitioner argues that the agreement limits the total number and class of cattle held by the partnerships. The provision establishing the number of cattle held by the partnerships clearly applies, by its terms, only to depreci

ts of the contract will be preferred to one that leaves portions of the contract meaningless." Rink v. Commissioner, 47 F.3d 168, 171 (6th Cir. 1995), affg. 100 T.C. 319 (1993); 2 Restatement, Contracts 2d, sec. 202 (1981); 4 Williston on Contracts, sec. 618 (3d ed. 1961). Petitioner argues that the agreement limits the total number and class of cattle held by the partnerships. The provision establishing the number of cattle held by the partnerships clearly applies, by its terms, only to depreci

ts of the contract will be preferred to one that leaves portions of the contract meaningless." Rink V. Commissioner, 47 F.3d 168, 171 (6th Cir. 1995), affg. 100 T.C. 319 (1993); 2 Restatement, Contracts 2d, sec. 202 (1981); 4 Williston on Contracts, sec. 618 (3d ed. 1961). Petitioner argues that the agreement limits the total number and class of cattle held by the partnerships. The provision establishing the number of cattle held by the partnerships clearly applies, by its terms, only to depreci

ts of the contract will be preferred to one that leaves portions of the contract meaningless." Rink V. Commissioner, 47 F.3d 168, 171 (6th Cir. 1995), affg. 100 T.C. 319 (1993); 2 Restatement, Contracts 2d, sec. 202 (1981); 4 Williston on Contracts, sec. 618 (3d ed. 1961). Petitioner argues that the agreement limits the total number and class of cattle held by the partnerships. The provision establishing the number of cattle held by the partnerships clearly applies, by its terms, only to depreci

ts of the contract will be preferred to one that leaves portions of the contract meaningless." Rink v. Commissioner, 47 F.3d 168, 171 (6th Cir. 1995), affg. 100 T.C. 319 (1993); 2 Restatement, Contracts 2d, sec. 202 (1981); 4 Williston on Contracts, sec. 618 (3d ed. 1961). Petitioner argues that the agreement limits the total number and class of cattle held by the partnerships. The provision establishing the number of cattle held by the partnerships clearly applies, by its terms, only to depreci

Dow Chemical Co. v. Commissioner 51 T.C. 669 · 1969
Rose v. Commissioner 56 T.C. 185 · 1971
Lime Cola Co. v. Commissioner 22 T.C. 593 · 1954

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