IRCCourt RulingsJul 23, 1965
Train, Judge:
Respondent determined the following deficiencies and additions to tax in petitioners’ income taxes for the years in issue:
Year Docket No. Deficiency Additions to tax under sec. 6651(a) I.R.C. 1954
William B. and Emeline Leavens, Jr. 1956 2103-63 $18,007.95
1957 791-63 23,469.63
1958 791-63 27, Oil. 67
19…
IRCCourt RulingsJan 30, 2007
…t of the offsetting distribution from Plan 15105 was
$14,443; (4) an offsetting distribution of $30,623 was made from
Plan 15106 in satisfaction of petitioner's loan from Plan 15106;
and (5) petitioner made no employee contributions to Plan 15106.
The parties stipulated the accuracy of the Forms 1099-R, and no
evidence…
IRCCourt RulingsJul 31, 2000★ strong match
…3 to
reflect the following adjustments:
1992
1993
Contributions to the Neonatology Plan $20,000 $22,623
Administrator’s fees 1,000 1,000
1991 NOL from plan contributions 4,272
—
Subtotal 25,272 23,623
Less: P.S. 58 costs included in income 1,626
3,654
Adjustment 23,646
19,969
Respondent determined primarily that the di…
IRCCourt RulingsFeb 28, 2024related by meaning
d a refund may be ordered by
such court of any amount col lected within the period during
which the Secretary is prohibited from collecting by levy or through a proceeding in court under the provisions of [section 6213(a)] .
4. Coordination of Section 6501 and 6213 Rules
Section 6503, titled “ Suspension of running of …
IRCCourt RulingsNov 2, 1998
… respondent erroneously determined
that petitioner had taxable income in 1990 in the amount of
$408,623 as a result of a distr ibution from his IRA at USTCNY.
Although petitioner conceded that $408,623 was withdrawn from his
USTCNY IRA in 1990, he testified that he timely rolled these funds
into another qualified retir…
T.C. Memo. 1998-145 — Estate of Hilda Ashman, Deceased; Phillip Ashman, Personal Representative v. Commissioner IRCCourt RulingsApr 22, 1998
…y of consistency
doctrine in the tax refund case Building Syndicate Co. v. United
States
, 292 F.2d 623 (9th Cir. 1961), was "based substantially on the equitable nature of a refund proceeding." We disagree. The
Court did not explain that it was basing its decision on the
equitable nature of tax refund cases, rather, i…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCCourt RulingsMar 31, 2015related by meaning
ayer liable for tax if the taxpayer fails to pay the tax within 10 days
after notice and demand for payment. Section 6330(a) provides that no levy may be made on any property or right to property of any person unless the Secretary
has notified such person in writing of the right to a hearing before the levy is
made. Se…
ERISACourt RulingsAug 31, 2026
…, 458 F.3d
955, 967 (9th Cir. 2006) (en banc) ; Montour v. Hartford Life & Acc. Ins.
Co. , 588 F.3d 623, 631 (9th Cir. 2009). On remand, Liu may raise th is
issue, if appropriate. We express no views on this issue.
IRCCourt RulingsSep 15, 2005related by meaning
tinued...)
- 5 -
of the Secretary, and in the same manner as taxes. Sec.
6652(c) (4) (A).
Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and
demand, the Secretary can collect the tax by levy upon the
property belonging to the person, subject to …
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
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
.
77 FR 71321 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Nov 30, 2012
…ly benefit at URA is greater than—
From—
To—
2014
599
599
2,531
2,531
2015
611
611
2,582
2,582
2016
623
623
2,633
2,633
2017
636
636
2,688
2,688
2018
649
649
2,745
2,745
2019
663
663
2,803
2,803
2020
677
677
2,861
2,861
2021
691
691
2,922
2,922
2022
706
706
2,983
2,983
2023 or later
720
720
3,046
3,046
1
Table II-A.
2…
IRCCourt RulingsDec 11, 2003related by meaning
h the “objective of the safe
harbor provision” referred to by the Court of Appeals in Evans
Cooperage
. Petitioner’s failure to file a return prior to respondent’s issuance of the notice presents us with a situation
that is the exact opposite of that referred to in Evans
Cooperage
, where the filing of returns preceded…
76 FR 74699 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 1, 2011
…575
575
2,431
2,431
2014
586
586
2,477
2,477
2015
598
598
2,527
2,527
2016
610
610
2,577
2,577
2017
623
623
2,632
2,632
2018
636
636
2,687
2,687
2019
649
649
2,743
2,743
2020
663
663
2,801
2,801
2021
677
677
2,860
2,860
2022 or later
691
691
2,920
2,920
1
Table II-A.
2
Table II-B.
3
Table II-C.
* * * * *
Issued in Wash…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
IRCCourt RulingsJun 13, 2012
…ch the law permits. See Gregory v. Helvering, 293 U.S. 465
(1935); Davis v. United States, 282 F.2d 623, 627 (10th Cir. 1960). Clearly, the
structure of petitioners' McDonald's restaurant business (the operating company,
the S corporation management company, the ESOP, and the NQDCP) in place