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66 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 44 T.C. 623 — Leavens v. Commissioner
    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…
  2. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    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…
  3. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    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…
  4. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    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 …
  5. T.C. Memo. 1998-388 — Robert B. Keenan v. Commissioner
    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 Although petitioner conceded that $408,623 was withdrawn from his USTCNY IRA in 1990, he testified that he timely rolled these funds into another qualified retir…
  6. 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…
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  8. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  9. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  10. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    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…
  11. Court of Appeals for the Ninth Circuit — Liu v. Kaiser Permanente Employees Pension Plan for the Permanente Medical Group, Inc.
    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.
  12. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    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 …
  13. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    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’ …
  14. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    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 …
  15. 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 .
  16. 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…
  17. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    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…
  18. 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…
  19. 74 T.C. 651 — Judd v. Commissioner
    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…
  20. T.C. Memo. 2012-166 — Todd R. & Andrea Pedersen v. Commissioner
    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